In re Wendy G.-R.

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In re Wendy G.-R.

IN RE WENDY G.-R.*
(AC 46641)
Bright, C. J., and Suarez and Seeley, Js.

Syllabus

The respondent mother appealed to this court from the judgment of the
trial court terminating her parental rights with respect to her minor
child, W. W was born in Guatemala and immigrated to New Haven in
2018 with the respondent father. In 2019, following a sexual assault by
a family member, W was adjudicated neglected and committed to the
care of the petitioner, the Commissioner of Children and Families. From
mid-2019 through December, 2021, the Department of Children and
Families had limited and sporadic contact with the mother, who
remained in Guatemala, and between December, 2021, and August, 2022,
the mother did not respond to communications from the department.
The mother immigrated to New Haven in July, 2022. The department
was unaware of this until August, 2022, when the mother appeared,
unannounced, at a supervised visit between W and the father. Thereafter,
the department referred the mother to various services, with which she
was reluctant to engage until early 2023. Trial on the termination of
parental rights petition commenced in March, 2023. The petitioner ini-
tially alleged that, pursuant to statute (§ 17a-112 (j) (3) (D)), no ongoing
parent-child relationship existed between the mother and W. At the
conclusion of the evidentiary portion of the trial, the petitioner’s counsel
orally moved to amend the petition to add the adjudicatory ground of
failure to rehabilitate as to the mother, pursuant to § 17a-112 (j) (3) (B)
(i), ‘‘to conform to the proof elicited at trial.’’ In the absence of any
objection or request for a continuation, the trial court granted the motion
and, thereafter, terminated the respondents’ parental rights, determining,
inter alia, that the petitioner proved that the mother had failed to rehabili-
tate but not that an ongoing parent-child relationship between the mother
and W did not exist. Held:
1. The respondent mother could not prevail on her claim that she was denied
her due process right to the effective assistance of counsel during the
termination of parental rights proceeding: contrary to the mother’s asser-
tion, the fact that the petitioner sought to amend the petition at the
close of evidence was not, in and of itself, a reasonable ground on which
her counsel should have objected to the petitioner’s motion, as the

* In accordance with the spirit and intent of General Statutes § 46b-142
(b) and Practice Book § 79a-12, the names of the parties involved in this
appeal are not disclosed. The records and papers of this case shall be open
for inspection only to persons having a proper interest therein and upon
order of the court.
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In re Wendy G.-R.
applicable rule of practice (§ 34a-1 (d)) permitted an amendment at any
time prior to a final adjudication; moreover, the mother could not satisfy
her burden of demonstrating that her counsel’s failure to object to the
petitioner’s motion to amend the petition could not be explained by one
or more possible strategic reasons that were objectively reasonable, as
the record was bereft of any evidence of the actual strategy the mother’s
counsel employed when she did not object to the petitioner’s motion,
and, instead of developing a record of her counsel’s allegedly deficient
performance or any resulting prejudice by filing a motion to open or a
petition for a new trial, the mother merely claimed that the existing
record amply demonstrated that her counsel acted deficiently and that
her counsel’s lack of competency contributed to the termination of her
parental rights; furthermore, the only legally viable ground on which
the mother’s counsel could have objected to the petitioner’s motion to
amend the petition, namely, that the amendment amounted to unfair
surprise and that she needed additional time to respond adequately to
the failure to rehabilitate ground, was not objectively reasonable because
the record reflected that, at trial, the petitioner presented evidence
related to the failure to rehabilitate ground without objection, including
a copy of the specific steps ordered to facilitate the mother’s reunifica-
tion with W, a permanency plan study that supported a finding that the
mother had failed to satisfy her specific steps and, accordingly, had
failed to rehabilitate, the testimony of a department social worker with
respect to numerous issues that could interfere with the mother’s ability
to safely assume a responsible position in W’s life, and the testimony
of S, an expert in clinical and forensic psychology, that pertained to the
mother’s failure to rehabilitate; additionally, throughout the trial, the
mother’s counsel attempted to undermine such evidence through cross-
examination and by presenting evidence of the mother’s rehabilitative
efforts, and the mother did not assert that her counsel should have
presented any additional evidence or that additional time was necessary
to prepare stronger arguments to refute the failure to rehabilitate ground;
accordingly, this court was not persuaded that the failure of the mother’s
counsel to object to the petitioner’s motion to amend was objectively
unreasonable under the circumstances, and, even if the mother could
satisfy her burden of demonstrating that such failure was objectively
unreasonable, she failed to demonstrate that she was prejudiced by her
counsel’s incompetency.
2. The trial court properly determined that the respondent mother was
unable or unwilling to benefit from efforts to reunify her with W, and,
accordingly, it was unnecessary for this court to consider the merits of
the mother’s claim that the department failed to make reasonable efforts
to reunify her with W: the mother did not challenge any of the trial
court’s specific subordinate findings as clearly erroneous and, instead,
broadly challenged the court’s assessment of the degree to which she
was receptive to and utilized the services offered as well as its ultimate
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In re Wendy G.-R.
determination that she was unable or unwilling to benefit from the
department’s services; moreover, in its findings, the trial court outlined
the myriad efforts to reunify her with W that were made by the depart-
ment despite the challenges posed by a global pandemic and the danger
presented by the fact that the mother was residing in Guatemala until
July, 2022, and those efforts were, on their face, not so lacking as to
preclude a finding that the mother was unable or unwilling to benefit
from such services; furthermore, the petitioner demonstrated by clear
and convincing evidence that the mother had inconsistent communica-
tion with the department when she was in Guatemala, that she failed
to timely notify the department of her whereabouts prior to July, 2022,
that she was reluctant to engage in services offered by the department
prior to 2023, which detrimentally delayed her ability to gain critical
and necessary knowledge of how W’s needs changed following her
immigration to New Haven, and that, at the time of her evaluation by
S, the mother still demonstrated a lack of insight into W’s traumatic
experiences resulting from her relocation to the United States, particu-
larly her sexual abuse, and what was required for the mother to provide
W with a safe, nurturing, and supportive environment free from insecu-
rity.

Argued December 6, 2023—officially released May 2, 2024**

Procedural History

Petition by the Commissioner of Children and Fami-
lies to terminate the respondents’ parental rights with
respect to their minor child, brought to the Superior
Court in the judicial district of New Haven, Juvenile
Matters, and tried to the court, Conway, J.; judgment
terminating the respondents’ parental rights, from
which the respondent mother appealed to this court.
Affirmed.
Matthew C. Eagan, assigned counsel, for the appel-
lant (respondent mother).
Evan O’Roark, assistant solicitor general, with whom
were Kaelah M. Smith, assistant attorney general, and,
on the brief, William Tong, attorney general, for the
appellee (petitioner).
** May 2, 2024, the date that this decision was released as a slip opinion,
is the operative date for all substantive and procedural purposes.
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In re Wendy G.-R.

Opinion

SUAREZ, J. The respondent mother, Mirian R.,
appeals from the judgment of the trial court terminating
her parental rights as to her biological daughter, Wendy
G.-R., pursuant to General Statutes § 17a-112 (j) (3) (B)
(i).1 The respondent claims that (1) she was denied her
due process right to the effective assistance of counsel,
(2) the court improperly determined that the Depart-
ment of Children and Families (department) made rea-
sonable efforts to reunify her with Wendy, and (3) the
court improperly determined that she was unable or
unwilling to benefit from reunification services. We
affirm the judgment of the trial court.
In its memorandum of decision, the court set forth
the relevant facts and procedural history in this case:
In January, 2014, ‘‘Wendy . . . was born in Guatemala
to . . . [the respondent] and Santos G. [The respon-
dent and Santos] speak only Spanish and understand
little to no English. [Santos] attended three years of
school in Guatemala and the [respondent attended] four
years of school in Guatemala. [The respondent and San-
tos] read and write very little Spanish. In the fall [of]
2018, [Santos] and Wendy emigrated by bus from Guate-
mala to the Mexico/Texas border. [The respondent and
Santos] decided to have four year old Wendy accom-
pany [Santos] because it is easier for an adult to success-
fully cross the border if accompanied by a child. At the
border, [Santos] surrendered himself and Wendy to the
United States Immigration and Custom[s] Enforcement
(ICE) authorities. [Santos and Wendy] were detained
for two or three days and then released. [Santos] and
1
In the underlying action, the court terminated the parental rights of both
the respondent and Wendy’s biological father, Santos G., as to Wendy. Santos
has not appealed from that judgment. In this opinion, we refer to Mirian R.
as the respondent. Unless necessary to our analysis of the claims raised by
the respondent, in this opinion we need not and do not address the court’s
findings and conclusions with respect to Santos.
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Wendy journeyed on by bus to New Haven, initially
residing with relatives.
‘‘In January, 2019, [Santos] and his uncle engaged in
a physical altercation in New Haven. Both men had
been drinking alcohol prior to the altercation. Wendy
sustained head contusions during the fight and bystand-
ers observed five year old Wendy walking down the
street covered in beer and bleeding through the nose.
The petitioner, the Commissioner of . . . Children and
Families . . . was contacted and referred [Santos] for
a substance abuse evaluation. By June, 2019, [Santos]
and Wendy had moved three times and were then shar-
ing a room in a rooming house.
‘‘[Santos] sponsored2 his Guatemalan cousin’s entry
into the United States and on or about June 19, [2019],
[Santos] picked up his cousin, Juan Carlos G., from the
airport. Juan Carlos took up occupancy in [Santos’] and
Wendy’s room in the rooming house. [Santos] never
came home the night of June 22, [2019], and, therefore,
Wendy was left alone in the room with Juan Carlos. On
the morning of June 23, [2019], Wendy told [Santos that]
she was afraid of remaining in their room without him
and asked if she could go with him to work. [Santos]
declined Wendy’s request. Late on June 23, [2019], Wen-
dy’s babysitter brought Wendy to the emergency room
after Wendy disclosed she had been sexually assaulted
by Juan Carlos.3
‘‘On June 24, [2019], [the petitioner] invoked an
administrative, ninety-six hour hold and assumed tem-
porary custody of Wendy. An order of temporary cus-
tody . . . soon followed, and, on September 12, 2019,
2
‘‘[Santos] defined sponsorship to mean that [he] was responsible for his
cousin, Juan Carlos.’’
3
‘‘A medical examination revealed a tear to Wendy’s hymen. In a forensic
evaluation, Wendy disclosed [that Juan Carlos] had touched her vagina on
two occasions with his hands and she reported other provocative statements
by Juan Carlos. No arrests were ever made and [the respondent and Santos]
report that Juan Carlos ‘left’ (presumably the New Haven area or the country)
in August or November, 2022.’’
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Wendy was adjudicated neglected4 and committed to
the petitioner’s care. Wendy has remained continuously
in [the petitioner’s] care since June 24, 2019.5

‘‘On March 9, 2021, the court approved a permanency
plan of reunification with the respondent . . . in Gua-
temala. In January, 2022, [the petitioner] sought and
obtained approval to amend the permanency plan [for]
termination of parental rights and adoption. On January
11, 2022, given the change in permanency plans and
[the respondent’s] Guatemalan residency, the court, sua
sponte, appointed [the respondent] legal counsel. [The
respondent’s] court-appointed attorney filed her
appearance in the case on January 13, 2022. On March
14, 2022, [the petitioner] filed [a petition to terminate
the] parental rights . . . [of the respondent and San-
tos] Both [the respondent and Santos] were properly
served with the . . . [petition]6 and both were repre-
sented by [appointed] counsel throughout the termina-
tion proceedings.7
4
‘‘[In the neglect proceeding, Santos] was defaulted for his nonappearance
on September 12, [2019]. In September, 2019, [the petitioner] had yet to
effectuate service on [the respondent] in Guatemala, and, therefore, the
adjudication of neglect and commitment order entered without prejudice
to the respondent . . . . [Santos] credibly testified that he timely informed
[the respondent] of Wendy’s removal from his care.’’
5
‘‘Wendy has lived with her current foster family for the majority of her
stay in foster care, except for a brief period of time when, due to the foster
parents’ medical concerns and the pandemic, Wendy was removed.’’
6
‘‘[The respondent] was served via publication and [Santos] was abode
served.’’
7
‘‘The April 12, 2022 [termination of parental rights] plea hearing was a
virtual proceeding and [the respondent] was defaulted for her nonappear-
ance. However, given the [respondent’s] out-of-country status, the court
appointed [the respondent’s] already assigned counsel to also represent [the
respondent] for the purposes of the termination of parental rights petition.
[The respondent] never appeared in court, in person or virtually, until the
first day of the termination trial, March 8, 2023.
‘‘[Santos’] initial [termination of parental rights] plea date was continued
due to a lack of a Spanish interpreter. On May 17, 2022, [Santos] appeared
and was advised in Spanish of his rights.’’
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‘‘On May 19, 2022, a competency evaluation of [San-
tos] was ordered by the court, and on September 22,
2022, [Santos] was found competent. In July, 2022, [the
respondent] arrived in New Haven from Guatemala as
an undocumented person. [The department] did not
learn of [the respondent’s] local presence until late July
or August, 2022. Trial on the [termination of parental
rights petition] commenced on March 8, 2023, continued
on March 15, [2023], and [resumed] again to conclusion
on March 31, 2023. Both [the respondent and Santos]
appeared in person for the multiday . . . trial and both
were assisted by court interpreters throughout the . . .
trial.8 The petitioner initially alleged that [Santos] had
failed to [achieve a sufficient degree of personal rehabil-
itation] and that there exists no ongoing parent-child
relationship between [the respondent] and Wendy. At
the conclusion of the evidentiary portion of the . . .
trial, the petitioner orally moved to amend the [petition]
to add the adjudicatory ground of failure to rehabilitate
as to [the respondent]. Absent objection and any request
for a continuation,9 the oral motion was granted, and,
therefore, the adjudicatory date for purposes of the
[termination of parental rights petition] is March 31,
2023.10’’ (Footnotes altered; footnotes in original; foot-
notes omitted.)
Thereafter, the court set forth its findings and legal
conclusions with respect to the petition to terminate
the respondent’s parental rights as to Wendy. In the
adjudicative phase of the proceeding, the court deter-
mined that the department had made reasonable efforts
to reunify the respondent and Wendy. Alternatively,
‘‘Just prior to the commencement of trial on March 8, 2023, the court
8

advised the [respondent and Santos] of their rights in accordance with In
re Yasiel R., 317 Conn. 773, [120 A.3d 1188] (2015).’’
9
‘‘See Practice Book § 31a-1 (d).’’
10
‘‘The termination [petition was] initially filed on March 14, 2022. A
written motion to amend other aspects of the [petition] was granted on May
17, 2022.’’
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the court determined that the respondent was either
unwilling or unable to benefit from such reunification
efforts. The court also determined that the petitioner
proved that the respondent had failed to rehabilitate but
that the petitioner had failed to prove that an ongoing
parent-child relationship between the respondent and
Wendy did not exist. In the dispositional phase of the
proceeding, the court, guided by the considerations set
forth in § 17a-112 (k), determined that it was in Wendy’s
best interest to terminate the respondent’s parental
rights as to her. Thereafter, the respondent appealed
from the court’s judgment terminating her parental
rights as to Wendy.11 We will set forth the court’s analy-
sis in more detail as necessary in the context of the
claims raised in this appeal.
I
First, the respondent claims that she was denied her
due process right to the effective assistance of counsel
during the termination proceeding.12 We are not per-
suaded.
The following additional facts are relevant to this
claim. In the operative petition at the time of trial, the
11
We note that the attorney for the minor child filed a statement pursuant
to Practice Book § 67-13 indicating that he adopts the brief submitted by
the petitioner.
12
In her brief, the respondent states that she ‘‘does not believe that this
case requires any further evidentiary findings in that both the deficient
performance and prejudice are apparent upon an examination of the record
as it exists.’’ Nonetheless, in what she labels a matter for further review,
the respondent claims that our Supreme Court’s decision in In re Jonathan
M., 255 Conn. 208, 764 A.2d 739 (2001), ‘‘should be reconsidered to the
extent that it established the appropriate options available to a respondent
seeking to supplement the record in order to raise an ineffective assistance
of counsel claim [in a termination of parental rights proceeding].’’ The
respondent correctly acknowledges, however, that this court is bound by
the precedent of our Supreme Court. See, e.g., In re Kyreese L., 220 Conn.
App. 705, 720 n.8, 299 A.3d 296 (this court is bound by Supreme Court
precedent), cert. denied, 348 Conn. 901, 300 A.3d 1166 (2023). Thus, we
merely note that the respondent has preserved this issue.
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In re Wendy G.-R.

petitioner alleged, as grounds for termination of the
respondent’s parental rights, that there existed no ongo-
ing parent-child relationship pursuant to § 17a-112 (j)
(3) (D). On March 31, 2023, at the close of evidence,
the court asked counsel: ‘‘[J]ust for clarity, what are
the adjudicatory grounds that are alleged as to [the
respondent]? ‘Cause I only have no ongoing parent-
child relationship.’’ Counsel for the petitioner stated
that she believed that the petition had been amended,
but the court stated that it could not ‘‘find it.’’ Following
a recess, the petitioner’s counsel made an oral motion
to amend the petition by adding, with respect to the
respondent, the ground of failure to rehabilitate pursu-
ant to § 17a-112 (j) (3) (B) (i). The petitioner’s counsel
stated that the amendment was sought ‘‘to conform to
the proof elicited at trial.’’ The court asked if anyone
wanted to ‘‘be heard’’ with respect to the amendment,
to which counsel for the respondent and counsel for the
minor child each indicated that they had no objection.
Following this acquiescence to the amendment to the
termination of parental rights petition, counsel did not
further discuss the matter. The court thereafter heard
closing arguments. As stated previously in this opinion,
in its memorandum of decision, the court explicitly
stated that it had granted the petitioner’s motion to
amend the termination of parental rights petition in the
absence of an objection or any request for a continuance
in the trial. The court also referred to Practice Book
§ 31a-1 (d).13
For the first time on appeal, the respondent argues
that her counsel acted deficiently by failing to object
13
Practice Book § 31a-1 (d) provides: ‘‘A petition or information may be
amended at any time by the judicial authority on its own motion or in
response to the motions of any party prior to any final adjudication. When
an amendment has been so ordered, a continuance shall be granted whenever
the judicial authority finds that the new allegations in the petition or changes
in the information justify the need for additional time to permit the parties
to respond adequately to the additional or changed facts and circumstances.’’
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to the petitioner’s oral motion to amend the termination
of parental rights petition with respect to the respon-
dent at the close of evidence, after all the parties had
rested, to add an ‘‘entirely separate ground for termina-
tion,’’ namely, failure to rehabilitate pursuant to § 17a-
112 (j) (3) (B) (i). The respondent argues that ‘‘no rea-
sonable attorney would have failed to object to the
[petitioner] orally amending its petition in such a funda-
mental manner just prior to closing arguments.’’ In
arguing that counsel’s conduct fell below the standard
of reasonably effective assistance, the respondent con-
tends that ‘‘there can be no argument that [her] counsel
failed to object for some strategic reason that would
insulate her deficient performance from scrutiny.’’

The respondent also argues that there can be no
dispute that she was prejudiced by counsel’s deficient
performance because the court ultimately concluded
that the petitioner had failed to prove the sole ground
in the termination petition prior to the amendment—
the lack of a parent-child relationship. The respondent
argues that, ‘‘without the amendment to include the
ground of failure to rehabilitate, the respondent’s paren-
tal rights could not have been terminated.’’ The respon-
dent asserts that a proper objection ‘‘would likely have
been sustained’’ at trial and, for this reason, ‘‘the respon-
dent is able to meet the burden that the failure to object
contributed to the termination of her parental rights.’’
The respondent further contends that her counsel
should have objected because principles of due process
weigh against permitting the petitioner to essentially
engage in ‘‘a shell game’’ by alleging one or more
grounds in a petition to terminate parental rights and
then, at the close of a trial, seeking to amend a petition
to conform to the evidence presented at trial. According
to the respondent, if her counsel had properly objected
to and argued against the motion to amend, due process
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In re Wendy G.-R.

considerations would have compelled the court to have
sustained the objection.14
We next set forth the principles that guide our review.
‘‘Our Supreme Court has recognized that, ‘[i]n Connecti-
cut, a parent who faces the termination of his or her
parental rights is entitled, by statute, to the assistance
of counsel. General Statutes § 45a-717 (b).’ In re Alex-
ander V., 223 Conn. 557, 569, 613 A.2d 780 (1992). The
Supreme Court further has held, consistent with that
statutory right, that ‘a parent in a termination of parental
rights hearing has the right not only to counsel but to
the effective assistance of counsel.’ ’’ (Footnote omit-
ted.) In re Danyellah S.-C., 167 Conn. App. 556, 567,
143 A.3d 698, cert. denied, 323 Conn. 913, 150 A.3d
228 (2016).
‘‘In State v. Anonymous, 179 Conn. 155, 160, 425 A.2d
939 (1979), our Supreme Court set forth the following
standard for determining whether counsel has been
ineffective in a termination proceeding: ‘The range of
competence . . . requires not errorless counsel, and
not counsel judged ineffective by hindsight, but counsel
whose performance is reasonably competent, or within
the range of competence displayed by lawyers with
ordinary training and skill in [that particular area of
the] law. . . . The [respondent] must, moreover, dem-
onstrate that the lack of competency contributed to
the termination of parental rights.’ . . . ‘A showing of
incompetency without a showing of resulting prejudice
. . . does not amount to ineffective assistance of coun-
sel.’ . . . In re Matthew S., 60 Conn. App. 127, 132,
758 A.2d 459 (2000). ‘In making such a claim, it is the
responsibility of the respondent to create an adequate
record pointing to the alleged ineffectiveness and any
14
In her brief to this court, the respondent agrees with the petitioner,
however, that the trial court properly granted the motion in the absence of
any objection by her attorney.
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In re Wendy G.-R.

prejudice the respondent claims resulted from that inef-
fectiveness.’ In re Christopher C., 129 Conn. App. 55,
59, 20 A.3d 689 (2011). In the absence of findings by
the trial court in this regard, we directly review the trial
court record. See In re Dylan C., 126 Conn. App. 71,
90–91, 10 A.3d 100 (2011).’’ In re Jah’za G., 141 Conn.
App. 15, 35–36, 60 A.3d 392, cert. denied, 308 Conn. 926,
64 A.3d 329 (2013); see also In re Alexander V., supra,
223 Conn. 570 (in considering merits of unpreserved
claim that counsel in termination of parental rights pro-
ceeding rendered ineffective assistance, reviewing
court undertook plenary review of trial court record).
We are mindful that ‘‘[a] fair assessment of attorney
performance requires that every effort be made to elimi-
nate the distorting effects of hindsight, to reconstruct
the circumstances of counsel’s challenged conduct, and
to evaluate the conduct from counsel’s perspective at
the time. Because of the difficulties inherent in making
the evaluation, a court must indulge a strong presump-
tion that [the] conduct [of trial counsel] falls within the
wide range of reasonable professional assistance; that
is, [an appellant] must overcome the presumption that,
under the circumstances, the challenged action might
be considered sound trial strategy.’’ (Internal quotation
marks omitted.) Love v. Commissioner of Correction,
223 Conn. App. 658, 668, 308 A.3d 1040, cert. denied,
348 Conn. 958, 310 A.3d 960 (2024).
Although it is undisputed that the respondent did not
raise the issue of ineffective assistance before the trial
court, we note that, following the court’s judgment, the
respondent had an opportunity to develop a factual
record related to counsel’s allegedly deficient perfor-
mance and any resulting prejudice. Our Supreme Court
has explained ‘‘that General Statutes § 45a-719 provides
a number of alternatives through which a parent may
attempt to open the final judgment of termination and
assert a claim of ineffective assistance of counsel. The
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In re Wendy G.-R.

first option permits a motion to open the judgment in
accordance with General Statutes § 52-212 or General
Statutes § 52-212a. These provisions allow a four month
window from the date of judgment within which such
a motion may be brought.
‘‘Second, the principles governing the opening of
judgments at common law may also provide an indigent
parent a means of gaining a review of the adequacy of
trial counsel at the termination proceeding. It is a well-
established general rule that even a judgment rendered
by the court . . . can subsequently be opened [after
the four month limitation] . . . if it is shown that . . .
the judgment . . . was obtained by fraud . . . or
because of mutual mistake. . . . Thus, when a judg-
ment of termination is predicated on fraud or mutual
mistake and the indigent’s appointed counsel fails to
address these issues, presumably rendering the assis-
tance ineffective, the parent may have a remedy to open
the judgment at common law.
‘‘Finally . . . a parent may file a petition for a new
trial. See General Statutes § 52-582. Under this option,
a parent whose rights have been terminated has three
years within which to file a petition. General Statutes
§ 52-270 provides that the court may grant such a peti-
tion for reasonable cause. Although we express no opin-
ion as to whether a colorable claim of ineffective assis-
tance of counsel always will require a court to grant a
petition for a new trial under § 52-582, we note that this
court has long recognized that [t]he causes for which
new trials may be granted . . . are only such as show
that the parties did not have a fair and full hearing at
the first trial; and the words or for other reasonable
cause, mean other causes of the same general character
. . . .’’ (Citation omitted; footnotes omitted; internal
quotation marks omitted.) In re Jonathan M., 255 Conn.
208, 236–39, 764 A.2d 739 (2001).
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The respondent did not avail herself of any of the
foregoing opportunities to develop a record of her coun-
sel’s allegedly deficient performance or the prejudice,
if any, that resulted from such performance. As stated
previously in this opinion, however, she argues that the
record amply demonstrates that counsel acted defi-
ciently and that counsel’s lack of competency contrib-
uted to the termination of her parental rights. See foot-
note 12 of this opinion.
Because the claim of ineffective assistance arises
from trial counsel’s response to the petitioner’s motion
to amend, we observe that amendments to petitions to
terminate parental rights are permitted by our rules of
practice. Practice Book § 34a-1 (d) provides: ‘‘A petition
may be amended at any time by the judicial authority
on its own motion or in response to a motion prior to
any final adjudication. When an amendment has been
so ordered, a continuance shall be granted whenever
the judicial authority finds that the new allegations in
the petition justify the need for additional time to permit
the parties to respond adequately to the additional or
changed facts and circumstances.’’ An appellate court
reviews a trial court’s decision to grant a motion to
amend for an abuse of discretion, and discretion is
properly exercised when a court appropriately rules
on any request made for additional time to respond
adequately to new allegations. See, e.g., In re Carl O.,
10 Conn. App. 428, 437–38, 523 A.2d 1339 (concluding
that trial court did not abuse its discretion in granting
petitioner’s request to amend termination of parental
rights petition when request was made on eve of trial
and court had offered to grant respondents continu-
ances for purpose of responding to amendment), cert.
denied, 204 Conn. 802, 525 A.2d 964 (1987), and cert.
denied, 204 Conn. 802, 525 A.2d 964 (1987).
For the reasons previously discussed herein, the
record is bereft of any evidence of the actual strategy,
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if any, that the respondent’s counsel employed when
she did not object to the petitioner’s eleventh hour
motion to amend the petition. In this circumstance, we,
as a reviewing court, are mindful of the presumption
that counsel acted reasonably, and we must contem-
plate possible strategic reasons that might have sup-
ported counsel’s challenged actions before considering
whether those actions were objectionably reasonable.
This is the proper analytical path that governs claims
of ineffective assistance of counsel in habeas corpus
proceedings in which the record does not contain evi-
dence of the actual trial strategy, if any, underlying
trial counsel’s challenged conduct. See, e.g., Jordan v.
Commissioner of Correction, 341 Conn. 279, 290, 267
A.3d 120 (2021) (‘‘when trial counsel is not available to
testify . . . the court must contemplate the possible
strategic reasons that might have supported the chal-
lenged action and then consider whether those reasons
were objectively reasonable’’); Roman v. Commis-
sioner of Correction, 223 Conn. App. 111, 135, 307 A.3d
934 (2023) (‘‘[A]lthough [appellate counsel] did not pres-
ent arguments about the petitioner’s mental health and
competence on direct appeal, the petitioner did not
call [appellate counsel] to testify at the habeas trial to
explain why, and the petitioner did not offer any other
evidence of [appellate counsel’s] reasons for choosing
which claims to raise on direct appeal. In the absence
of such evidence, the petitioner did not otherwise meet
his burden of overcoming the strong presumption that
[appellate counsel] exercised reasonable professional
judgment.’’), cert. denied, 348 Conn. 952, 308 A.3d 1039
(2024); Godfrey-Hill v. Commissioner of Correction,
221 Conn. App. 526, 543–44, 302 A.3d 923 (when trial
counsel cannot recall trial strategy, court must ‘‘affirma-
tively entertain the range of possible reasons [that]
counsel may have had for proceeding as [he] did’’ (inter-
nal quotation marks omitted)), cert. denied, 348 Conn.
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929, 304 A.3d 861 (2023); Crocker v. Commissioner
of Correction, 220 Conn. App. 567, 585, 300 A.3d 607
(‘‘although not automatically fatal to a petitioner’s
claim, failure to elicit testimony from counsel about
trial strategy renders it less likely that the petitioner
can prevail with respect to his burden to demonstrate
deficient performance’’), cert. denied, 348 Conn. 911,
303 A.3d 10 (2023); Bush v. Commissioner of Correc-
tion, 169 Conn. App. 540, 550, 151 A.3d 388 (2016)
(‘‘There is a strong presumption that counsel has ren-
dered adequate assistance and made all significant deci-
sions in the exercise of reasonable professional judg-
ment. . . . Just as the decision of trial counsel not to
object to certain evidence is a matter of trial tactics, not
evidence of incompetency . . . the tactical decision of
appellate counsel not to raise a particular claim is ordi-
narily a matter of appellate tactics, and not evidence of
incompetency, in light of the presumption of reasonable
professional judgment.’’ (Internal quotation marks
omitted.)), cert. denied, 324 Conn. 920, 157 A.3d 85
(2017). We see no reason, and the respondent has not
cited any relevant authority to the contrary, why this
analytical path should not apply to the present claim
of ineffective assistance of counsel.
Contrary to the respondent’s arguments on appeal,
because Practice Book § 34a-1 (d) permits amendments
at any time prior to any final adjudication, the fact that
the petitioner sought to amend the petition at the close
of evidence was not, in and of itself, a reasonable ground
on which to object to the petitioner’s motion. The
respondent also strongly emphasizes that counsel
should have advanced due process concerns as the
grounds for objecting to the motion. As the respondent
correctly observes, the fundamental pillars of due pro-
cess encompass adequate notice of the grounds on
which the petitioner relies so that the respondent has
‘‘a reasonable opportunity to prepare’’ and a right to
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In re Wendy G.-R.

be heard. See In re P. T.-W., 223 Conn. App. 571, 584–85,
309 A.3d 394 (2024) (‘‘[i]t is the settled rule of this
jurisdiction, if indeed it may not be safely called an
established principle of general jurisprudence, that no
court will proceed to the adjudication of a matter involv-
ing conflicting rights and interests, until all persons
directly concerned in the event have been actually or
constructively notified of the pendency of the proceed-
ing, and given reasonable opportunity to appear and be
heard’’ (internal quotation marks omitted)). Neverthe-
less, § 34a-1 (d) does not, as the respondent suggests,
condone ‘‘a shell game . . . .’’ It permits the petitioner
to amend the petition, thereby giving the respondent
actual notice of the statutory grounds for termination
of parental rights on which it intends to rely.15 It also
provides a clear mechanism to protect the respondent’s
right to prepare and be heard by requiring the court
to afford the respondent additional time to respond
adequately to the additional or changed facts and cir-
cumstances.16 See Practice Book § 34a-1 (d).
15
In this regard, we note that Practice Book § 34a-1 (d) uses the word
‘‘shall,’’ thus triggering a mandatory duty on the part of the court to afford
a respondent the time necessary to respond adequately to any amendments.
See, e.g., In re Adrien C., 9 Conn. App. 506, 509, 519 A.2d 1241 (observing
for purposes of statutory interpretation that ‘‘the word ‘shall’ is generally
determined to be mandatory’’), cert. denied, 203 Conn. 802, 522 A.2d 292
(1987).
16
As our Supreme Court has observed, ‘‘[i]t is well established that a
person in jeopardy of having his or her parental rights terminated has
a constitutional due process right to adequate notice of the grounds for
termination. . . . Notice is not a mere perfunctory act in order to satisfy
the technicalities of a statute, but has, as its basis, constitutional dimensions.
An elementary and fundamental requirement of due process in any proceed-
ing [that] is to be accorded finality is notice reasonably calculated, under
all the circumstances, to apprise interested parties of the pendency of the
action and afford them an opportunity to present their objections. . . .
Notice, to comply with due process requirements, must be given sufficiently
in advance of scheduled court proceedings so that [a] reasonable opportunity
to prepare will be afforded, and it must set forth the alleged misconduct
with particularity. . . . [T]here is no violation of due process when a party
in interest is given the opportunity at a meaningful time for a court hearing
to litigate the question [at issue].’’ (Citations omitted; internal quotation
marks omitted.) In re Gabriel S., 347 Conn. 223, 232–33, 296 A.3d 829 (2023).
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With respect to the present claim, the respondent, in
order to satisfy her burden of proving that counsel
rendered deficient representation, must do more than
demonstrate that counsel failed to object to the motion
to amend. Instead, she must demonstrate that counsel’s
failure to object cannot be explained by one or more
possible strategic reasons that are objectively reason-
able. The respondent cannot satisfy that burden. It
appears that the only legally viable ground on which
the respondent’s counsel might have objected was, as
the respondent suggests, on the ground that the amend-
ment amounted to unfair surprise and that she needed
additional time to respond adequately to the failure to
rehabilitate ground. If counsel pursued such an objec-
tion, however, the remedy to which the respondent
would have been entitled was additional time.

Such an objection does not appear to be objectively
reasonable in the present case because, as the respon-
dent acknowledges before this court, the record reflects
that, prior to the motion, the petitioner presented evi-
dence related to the failure to rehabilitate ground. We
briefly observe that, at the time of the trial, although
the petition set forth the sole ground of no ongoing
parent-child relationship, the petitioner nonetheless
presented a copy of the respondent’s court-ordered spe-
cific steps to facilitate the respondent’s reunification
with Wendy. The petitioner also presented a perma-
nency plan study dated September 30, 2022, which sup-
ported a finding that the respondent had failed to satisfy
her specific steps and, thus, had failed to rehabilitate.
In the absence of any objection, the petitioner presented
testimony from a department social worker with
respect to numerous unresolved issues that could inter-
fere with the respondent being able to safely assume
a responsible position in Wendy’s life. There was evi-
dence that, in 2022, the respondent’s youngest child
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was found outdoors, at night, in a city street. The peti-
tioner also presented testimonial evidence from a
department social worker that was relevant to the issue
of the respondent’s failure to rehabilitate.
Furthermore, the record reflects that the respon-
dent’s counsel challenged the failure to rehabilitate
ground through cross-examination and by presenting
evidence of the respondent’s rehabilitative efforts. For
example, during cross-examination of the social
worker, the respondent’s counsel elicited testimony
from the social worker that tended to demonstrate that
the respondent’s residence was clean and that she had
satisfied her specific step requiring her to consistently
visit with Wendy. The respondent also testified with
respect to the 2022 incident, in which she allegedly had
failed to adequately supervise her youngest child. The
respondent testified that, while she was cooking food,
the child had wandered off briefly and was found at
the edge of a city street.
The petitioner presented testimony from Tina Schi-
appa, an expert in clinical and forensic psychology who
had evaluated the respondent. Several portions of Schi-
appa’s examination pertained to the respondent’s fail-
ure to rehabilitate. Schiappa testified that she had evalu-
ated the respondent’s ‘‘ability to parent.’’ Without
objection, counsel for the petitioner asked Schiappa
whether she believed that the respondent ‘‘ha[d] reha-
bilitated to the point where Wendy could be returned
to her care today?’’ Schiappa replied in the negative.
Counsel for the petitioner also asked Schiappa, ‘‘[G]iven
the age and needs of Wendy, do you think [the respon-
dent] should be given more time to achieve . . . that
level of understanding that she could get through coun-
seling and classes . . . in order for Wendy to be safely
reunified with her?’’ Schiappa opined that it was not
‘‘fair’’ for Wendy to have to wait for that and that she
did not believe that the respondent should be given
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additional time. Moreover, during the cross-examina-
tion of Schiappa, the respondent’s counsel attempted
to undermine these opinions in various ways. Counsel
for the respondent also asked Schiappa questions that
were relevant to the respondent’s alleged failure to reha-
bilitate, such as whether she believed that the respon-
dent should have been afforded ‘‘a little bit more time
. . . once she got here to do services?’’
An examination of the record reflects that, without
objection at trial, the petitioner presented evidence that
was relevant to the issue of whether the respondent
had failed to rehabilitate. The respondent’s counsel
attempted to undermine this evidence throughout the
trial. Unless the respondent’s counsel had new evidence
to present with respect to the failure to rehabilitate
ground, believed that additional examination of the peti-
tioner’s witnesses would be beneficial to dispute the
new ground, or she simply needed additional time to
prepare for closing argument, it would not have been
a reasonable trial strategy to object to the motion to
amend the petition for the purpose of seeking additional
time. The respondent has failed to present any evidence
as to what additional steps her counsel could or should
have taken had she been given additional time in which
to respond to the new ground. In fact, the respondent
does not assert that her counsel should have presented
any additional evidence or that additional time was
necessary to prepare stronger arguments to refute the
failure to rehabilitate ground. For these reasons, we
are not persuaded that counsel’s failure to object to the
petitioner’s motion to amend was objectively unreason-
able under the circumstances of this case.
Even if the respondent could satisfy her burden of
demonstrating that it was objectively unreasonable for
her counsel not to object to the motion to amend on
the basis of the only ground on which she could object,
namely, that she needed more time to defend against the
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new adjudicative ground, she has failed to demonstrate
that she suffered prejudice in that counsel’s incompe-
tency contributed to the loss of her parental rights. In
the present case, the respondent does not present us
with a record to demonstrate what additional evidence
or argument her counsel should have presented if she
had asked for additional time to respond to the amend-
ment. In fact, she does not even argue that there was
anything that her counsel should have done differently
to respond to the amendment.17 Instead, the respondent
argues that prejudice is readily apparent in this case
because the court ultimately relied on the failure to
rehabilitate ground. For the reasons already discussed
in this opinion, that argument is fundamentally flawed.
The respondent’s argument overlooks the fact that our
rules of practice permit the petitioner to amend a termi-
nation of parental rights petition at any time prior to
a final adjudication of the petition, provided that the
respondent is afforded additional time as necessary to
respond to the amendment. See Practice Book § 34a-1
(d). As we have already concluded, the respondent has
not demonstrated that it was objectively unreasonable
for her counsel not to request additional time in light
of the facts of this case.
17
With respect to this type of a claim, a respondent is unable to demon-
strate that he or she suffered prejudice simply because the court subse-
quently rendered an adverse judgment. See, e.g., In re Gabriel S., 347 Conn.
223, 238, 296 A.3d 829 (2023) (‘‘[t]o the extent that the respondent claims
that he did not receive adequate notice that his failure to rehabilitate would
be one of the grounds for terminating his parental rights when the trial
continued because it was possible that the petitioner would proceed under
[§ 17a-112 (j) (3) (B) (i)], any constitutional violation was harmless beyond
a reasonable doubt because he makes no claim that there was additional
evidence on that issue that he would have presented if he had received
adequate notice’’); In re Ivory W., 342 Conn. 692, 732 n.6, 271 A.3d 633
(2022) (suggesting that, even if trial court improperly denied motion for
continuance in termination of parental rights proceeding, denial was harm-
less because ‘‘the respondent [mother never] explained how the testimony
that she would have given if the trial court had granted her motion for a
continuance would have affected the outcome of the termination proceed-
ing’’).
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In re Wendy G.-R.

On the basis of the foregoing, we reject the respon-
dent’s claim that her trial counsel rendered ineffective
assistance at the termination of parental rights trial.
II
The respondent next raises two claims of error
related to the court’s determinations made pursuant to
§ 17a-112 (j) (1). Specifically, the respondent claims
that the court improperly determined that (1) the
department made reasonable efforts to reunify her with
Wendy, and (2) she was unable or unwilling to benefit
from reunification efforts.18 We conclude that the court
properly determined that the respondent was unable
or unwilling to benefit from reunification efforts. Given
our resolution of this claim, it is unnecessary for us to
consider the merits of her claim that the department
failed to make reasonable efforts to reunify the respon-
dent and Wendy.19
18
General Statutes § 17a-112 (j) provides in relevant part: ‘‘The Superior
Court, upon notice and hearing as provided in sections 45a-716 and 45a-
717, may grant a petition filed pursuant to this section if it finds by clear
and convincing evidence that (1) the [department] has made reasonable
efforts to locate the parent and to reunify the child with the parent in
accordance with subsection (a) of section 17a-111b, unless the court finds
in this proceeding that the parent is unable or unwilling to benefit from
reunification efforts, except that such finding is not required if the court
has determined at a hearing pursuant to section 17a-111b, or determines at
trial on the petition, that such efforts are not required, (2) termination is
in the best interest of the child, and (3) . . . (B) the child (i) has been
found by the Superior Court . . . to have been neglected, abused or uncared
for in a prior proceeding . . . and the parent of such child . . . has failed
to achieve such degree of personal rehabilitation as would encourage the
belief that within a reasonable time, considering the age and needs of the
child, such parent could assume a responsible position in the life of the
child . . . .’’
19
Our Supreme Court has stated that, ‘‘[b]ecause the two clauses [of § 17a-
112 (j) (1)] are separated by the word ‘unless,’ this statute plainly is written
in the conjunctive. Accordingly, the department must prove either that it
has made reasonable efforts to reunify or, alternatively, that the parent is
unwilling or unable to benefit from reunification efforts. . . . [E]ither show-
ing is sufficient to satisfy this statutory element.’’ (Emphasis in original.)
In re Jorden R., 293 Conn. 539, 552–53, 979 A.2d 469 (2009).
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In re Wendy G.-R.

We begin by setting forth additional findings of the
court. Even though, as we have stated, we need not
consider the merits of the respondent’s claim regarding
the reasonableness of the efforts made by the depart-
ment to reunify her with Wendy, we nevertheless set
forth the court’s findings and conclusions concerning
those efforts because those efforts are relevant to the
claim that the court improperly determined that she was
unable or unwilling to benefit from the department’s
rehabilitative efforts. ‘‘[The department] made reason-
able efforts to locate [the respondent]. As noted above,
[the respondent] (who was pregnant with Yeni20 at the
time [Santos] and Wendy left Guatemala in 2018)
remained behind in Guatemala. [Santos] provided [the
department] with [the respondent’s] cell phone number
in Guatemala and credible testimony revealed that vari-
ous [department] social workers assigned to the case
from mid-2019 to December, 2021, had contact, albeit
limited and intermittent . . . with [the respondent], via
cell phone or through the use of the WhatsApp app (a
free virtual communication platform commonly used
to video chat and/or text, particularly overseas).

‘‘[Santos] testified that [the respondent] always had
access to a cell phone in Guatemala and he would
video call [the respondent] during his weekly in-person
supervised visitation sessions with Wendy so that [the
respondent] and Wendy could visit with one another.
[The respondent] also testified that [Santos] would
video call her during his weekly visits with Wendy and
Wendy and [the respondent] virtually connected with
one another. [The respondent] also had some degree
of cellular or video communication, independent from
[the department], with Wendy and Wendy’s foster fam-
ily.
20
The court found that Yeni is Wendy’s younger sister and that Yeni
immigrated with the respondent to New Haven in July, 2022.
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In re Wendy G.-R.

‘‘In July, 2019, Attorney Jennifer Avenia, the Director
of Immigration Practice for [the department], was con-
sulted for her expertise on how the [department] could
best serve the family. [Avenia’s] recommendations in
this case included (1) referrals for local services to
assist [Santos] and Wendy, (2) securing Wendy special
immigrant juvenile status,21 and (3) exploring the poten-
tial reunification of Wendy with [the respondent] in
Guatemala.
‘‘The potential reunification of [the respondent] and
Wendy in Guatemala required pursuing a study of [the
respondent] and the family’s Guatemalan home. [The
department] reached out to International Social Ser-
vices (ISS-USA) to conduct the out-of-country study. In
December, 2019, ISS-USA shared a completed study
with [the department], which recommended [that]
Wendy be reunified with [the respondent] in Guatemala.
‘‘The family’s home22 is located in Jocotán, Guate-
mala. Jocotán is a rural village or municipality in the
Chiquimula department of Guatemala. [Avenia] credibly
testified [that] Jocotán is not far from the Honduras
border, Guatemala experiences a high homicide rate,
and Chiquimula has the third highest homicide rate in all
of Guatemala. Additionally, Guatemala’s rainy season
spans from approximately May to October, and road-
ways in and around Jocotán, Chiquimula are dirt roads
which can wash out in the rainy season, thereby making
road travel only possible with SUV-like vehicles. [The
respondent] does not own a motor vehicle, and,
according to the ISS-USA report (which was not placed
in evidence nor shared with the court), [the respon-
dent’s] available modes of transportation [are] by foot
or horseback. Nonetheless, [the respondent] credibly
21
‘‘Special juvenile immigration status potentially affords Wendy a path
to United States citizenship.’’
22
‘‘The family home in Guatemala is a single dirt floor room. The home
has no indoor plumbing. Beds are rope woven entities.’’
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26 ,0 0 Conn. App. 1
In re Wendy G.-R.

testified that a bus ride she undertook in 2019 from her
Jocotán home to Guatemala City (the country’s capital)
took twelve hours. An international airport is located
just outside Guatemala City. [Avenia] testified that the
United States State Department categorizes Guatemala
as a country in which travelers from abroad should
‘reconsider travel.’23
‘‘Given ISS-USA’s December, 2019 recommendation
of reunification, in early 2020, [the department]
attempted to formulate a plan to safely return Wendy
to [the respondent] in Guatemala. [Avenia] was told
that Wendy’s passport was lost or stolen or taken at
the Mexico/Texas border. In reality, Wendy was never
issued a passport. In an attempt to arrange for Wendy’s
legal entry back into Guatemala in 2020, [the depart-
ment] reached out to the Guatemalan consulate seeking
a passport for Wendy. However, the Guatemalan gov-
ernment engaged in only minimal contact with [the
department]. Ultimately, sometime between April and
June, 2020, the Guatemalan government issued Wendy
a one-way travel visa into Guatemala.24
23
‘‘The court takes judicial notice of the United States Travel Advisory
System, which is comprised of four levels. Level 1 recommends exercising
normal precautions, Level 2 recommends exercising increased caution, Level
3 recommends reconsidering travel, and Level 4 recommends do not travel.
Guatemala is a Level 3 country.’’
24
‘‘[The respondent] testified that, while pregnant with her daughter, Yeni
(born [in] 2019), [the respondent] traveled by bus from her Jocotán home
to Guatemala City to obtain a passport for Wendy. ([The respondent] was
unsuccessful in procuring Wendy a passport.) The [respondent and Santos]
sought to obtain a passport for Wendy in 2019 because they wanted Wendy
to return to [the respondent’s] care in Guatemala (apparently with [Santos]
remaining in the United States). [Santos] credibly testified that [he and
the respondent] reconsidered that decision as Wendy began speaking and
understanding more English than Spanish. [The respondent] expressed to
[Santos] a concern that if Wendy were to return to her care in Guatemala,
[the respondent] would not be able to understand what Wendy was saying
in English.
‘‘The Guatemalan government’s meager responses to [the department’s]
overtures and the Guatemalan consulate’s 2020 decision to only issue Wendy
a one-way visa appears to have been driven, in whole or in part, by the
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In re Wendy G.-R.

‘‘Thereafter, [the department] assessed the options of
sending Wendy, accompanied by a [department] social
[worker], to Guatemala and/or sending six year old
Wendy unaccompanied to Guatemala. Formulating a
plan to return Wendy to [the respondent] in Guatemala
in mid-2020 included navigating the global challenges
attendant to the COVID-19 pandemic. After carefully
considering the profound health risks associated with
traveling abroad in the pandemic, and the State Depart-
ment’s travel advisory warning, and the homicide rate
in Guatemala (and, particularly, in the department of
Chiquimula), [the department] concluded any attempt
to return Wendy to Guatemala in 2020 posed unaccept-
able health and safety risks to Wendy and [depart-
ment] staff.25
COVID-19 pandemic. It is noteworthy that, had the [respondent and Santos]
secured a passport for Wendy prior to the pandemic or prior to Wendy’s
and [Santos’] 2018 departure from Guatemala, [the department] could have
contemplated flying Wendy into Guatemala secure in knowing that if [the
respondent] did not timely appear at the Guatemalan airport, Wendy could
return to the United States and remain in [the petitioner’s] custody.’’
25
‘‘A[n] extremely compelling concern for [the department] in 2020 was
whether [the respondent] would/could actually timely appear at the Guate-
malan airport to assume physical custody of Wendy. In 2020, [the respondent]
was not maintaining reliable or consistent contact with [the department].
Per [the respondent], it is a twelve hour bus ride from her home to Guatemala
City and, as noted previously, the airport is located just outside of the capital
city. [The department] was justified in its decision that it was not appropriate
for [department] social workers to travel with Wendy from the Guatemalan
airport to Jocotán, assuming road travel was even possible. As noted . . .
the Guatemalan government’s one-way visa precluded Wendy from returning
to the United States once she entered Guatemala. As discussed previously,
[the department] had justified concerns about the safety and well-being of
their [department] social workers staying indefinitely anywhere in Guate-
mala, both due to the health risks posed by the pandemic in 2020 and the
physical safety of travelers to Guatemala given the State Department’s rating.
[The department] also vetted a contingency plan of turning Wendy over to
Guatemalan child protection officials if [the respondent] did not appear.
[The department] appropriately concluded [that] subjecting Wendy to Guate-
mala’s less than robust foster care system, in the midst of a global pandemic,
with a military that is known for seeking and obtaining bribes, was not in
Wendy’s best interests.’’
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28 ,0 0 Conn. App. 1
In re Wendy G.-R.

‘‘In early 2022, [Avenia] recommended the 2019 ISS-
USA study be updated/repeated to determine if reunifi-
cation with [the respondent] in Guatemala was a viable
possibility in 2022.26 When ISS-USA attempted to make
contact with [the respondent] in Guatemala in 2022,
[the respondent] could not be contacted or located.
Unbeknownst to ISS-USA and to [the department], [the
respondent] left Guatemala with her younger daughter,
Yeni, paying a ‘coyote’27 to secure her and Yeni’s passage
to the Mexico/Texas border. Although [the respondent]
and Yeni arrived in New Haven on or about July 10,
2022, [the department’s] first 2022 contact with [the
respondent] did not occur until [the respondent]
appeared, unannounced, at an in-person supervised
father-daughter visit in August, 2022. [The respondent]
testified she did not reach out to [the department] prior
to her August, 2022 appearance at the father-daughter
supervised visit because she did not have a cell phone.28
‘‘In September, 2022, [the department] referred [the
respondent] to [Integrated Refugee and Immigrant Ser-
vices (IRIS)]. For an immigrant’s first two years in New
Haven, IRIS will work with individuals requiring assis-
tance. By November, 2022, [the respondent] had yet to
engage with the IRIS worker. The IRIS worker therefore
reached out to [the respondent’s] counsel. IRIS was
able to finally convince [the respondent] to meet and
IRIS conducted its first home visit with [the respondent]
26
‘‘By 2022, the 2019 ISS-USA study had expired.’’
27
This court previously has observed that ‘‘coyote’’ is a slang word that
refers to ‘‘a person paid to guide children . . . and other persons to and
across the United States border.’’ In re Pedro J. C., 154 Conn. App. 517, 523
n.4, 105 A.3d 943 (2014), overruled in part on other grounds by In re Henrry
P. B.-P., 327 Conn. 312, 173 A.3d 928 (2017).
28
‘‘Again, according to [Santos], [the respondent] ‘always’ had cellular and/
or virtual platform communication accessibility in Guatemala. It is unknown
what [the respondent’s] cell phone access was en route to the United States.
However, what is known, is that upon arriving in New Haven in mid-July,
2022, [the respondent] and her younger daughter, Yeni, resided with [Santos]
and [Santos] had cell phone/virtual platform capability.’’
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in December, 2022. [The respondent] continued to be
unwilling to share necessary background information
with IRIS and [the respondent] would not engage with
IRIS. It took [approximately five] months for the IRIS
worker to establish a trusting, working relationship
with [the respondent].29 Since February, 2023, IRIS has
been assisting [the respondent] and [the respondent] is
engaging with the IRIS worker.
‘‘In late August, 2022, New Haven police responded
to a call that Wendy’s three year old sister, Yeni, had
been found unsupervised standing/walking in the
streets of New Haven. When [the respondent] appeared
at the scene, [the respondent] appeared to be under
the influence. She was arrested for risk of injury [to a
child].30
‘‘After Yeni was found unsupervised in the street, [the
department] referred [the respondent] for a substance
abuse evaluation and there were no recommendations
for follow-up treatment. [The department] also referred
[the respondent] to [Intensive Family Preservation
(IFP)], an in-home, parenting education and coaching
service. The IFP worker continues to partner with IRIS
to encourage [the respondent] to engage with IRIS and
in obtaining community based social and legal services.
‘‘Since August, 2022, [the respondent] and Wendy
have enjoyed weekly supervised visits facilitated by [the
department] and/or a supervised visitation center. Both
[the respondent and Santos] . . . participate in the
family visits with Wendy. At times during the visits,
the family requires the assistance of an interpreter.31
[Santos] testified that Wendy speaks a lot more English
29
‘‘The IRIS worker credibly testified that, in her experience, distrust and a
reluctance to engage is not uncommon with the population she works with.’’
30
‘‘The criminal case was eventually dismissed.’’
31
‘‘[Department] social worker [Kelly] Tibault testified that, if a Spanish
speak[ing] worker or interpreter is not present at the supervised visits, the
Google Translate app is utilized.’’
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than she does Spanish. According to [Santos], Wendy’s
lack of fluency in Spanish played a part in [his and
the respondent’s] reconsidering sending Wendy back
to [the respondent’s] care in Guatemala. Reportedly,
Wendy understands spoken Spanish more than she can
speak it, and she requires a translator for some of her
verbal exchanges with [Santos and the respondent]. To
enhance communication between [Santos, the respon-
dent] and Wendy, [the department] explored enrolling
Wendy in Spanish language classes. Wendy declined
Spanish language classes, claiming she learns better
(Spanish) listening to her bilingual foster parents (and
foster siblings) speak Spanish at home.
‘‘From July, 2022, to February, 2023, [the respondent]
and Yeni primarily resided with [Santos] in a rooming
house on Kimberly Avenue in New Haven. . . . [T]he
rooming house’s common area was observed to have
sticky floors, bugs, and cockroaches.32 [The depart-
ment] attempted to screen the other rooming house
tenants and view their individual rooms. Presumably
because of the tenants’ undocumented status, some
refused to interact with [the department] and [the
department] could not adequately vet the other occu-
pants or assess the physical structure of the rooming
house (as to potential safety or hazardous issues appli-
cable to a three year old). In mid-February, 2023, [the
respondent] and Yeni began renting a room from an
unrelated male acquaintance in another rooming house
in New Haven, which [the department] assesses is
appropriate for [the respondent] and Yeni.
‘‘[The respondent] works as an undocumented
worker at a Mexican restaurant. [The respondent] and
32
‘‘The house refrigerator contained mold and had a foul odor. Like [Santos
and the respondent], [the department] surmised that the others in the room-
ing house work in the food service-restaurant business and their dietary
needs, in large part, are met with ‘take-out’ food, presumably from where
they work.’’
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Yeni subsist in part on food from the restaurant and
food donations from providers such as IRIS. One of the
social/parenting issues IRIS and IFP were addressing
with [the respondent] as recently as February and
March, 2023, is the importance of securing safe and
responsible child care for Yeni when [she is] not in [the
respondent’s] care.33
‘‘Wendy was referred for mental health treatment to
address the trauma and uncertainties she experienced
in her young life, the journey to this country and ICE
detention, the physical violence she witnessed and
experienced while living with [Santos] in 2019, the sex-
ual assault she endured by Juan Carlos . . . and [San-
tos’] failure to keep her safe, her removal from [Santos’]
care and entry into foster care, and the substantive loss
of contact with [the respondent] from the latter part of
2018 to August, 2022. Wendy last discharged success-
fully from counseling in November, 2022. By all
accounts, Wendy is an outgoing, resilient, and
healthy child.
‘‘The testimony and evidence reflect that, from 2019
through the end of 2021, [the respondent] had limited,
sporadic contact with the various assigned [depart-
ment] social workers and [the respondent] joined in
virtually on [Santos’] and Wendy’s supervised visitation
sessions. In December, 2021, through August, 2022,
[department] social worker [Kelly] Tibault unsuccess-
fully attempted contact with [the respondent], either
directly ‘dialing’ the cell phone number provided by
[Santos] or through the use of the WhatsApp messenger
app. . . . Tibault routinely texted [the respondent]
through the WhatsApp platform. [The respondent] did
not respond.
33
‘‘In January, 2023, [the petitioner] filed a neglect petition as to Yeni.
Said neglect petition remain[ed] pending [at the time of the trial court’s
judgment].’’
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‘‘[The department] was unaware of [the respondent’s]
2022 emigration from Guatemala until after [the respon-
dent’s] July, 2022 arrival to New Haven. It may be [that
the respondent’s] lack of communication with [the
department] in 2022 was tied to her decision to emigrate
and the actual journey to Connecticut. Nonetheless,
when ISS-USA attempted to connect with [the respon-
dent] to complete an updated and/or second home study
in 2022, [the respondent] could not be contacted or
located. [The department] did not become aware of
[the respondent’s] and Yeni’s July, 2022 arrival to New
Haven until very late July/early August, 2022, and by
late August, 2022, [the department] began attempting
to engage with [the respondent] and to refer [the respon-
dent] to IRIS, IFP, substance abuse evaluation, and
weekly supervised visitation sessions with Wendy.34
‘‘Case law is clear [that] reasonable efforts is defined
as doing everything reasonable, not everything possible.
Clearly, the barriers to reunifying Wendy with [the
respondent] in Guatemala could not be mitigated in
2020. However, had [the respondent] responded to [the
department’s] repeated attempts to communicate with
her in 2022, and had [the respondent] made herself
available for the second ISS-USA study in Guatemala,
returning Wendy to Guatemala in 2022 (as the world
emerged from the constraints of the pandemic) may
have been possible (assuming a favorable and current
ISS-USA study).
‘‘Since [the respondent’s] and Yeni’s August, 2022
arrival to New Haven, [the department] has attempted
to work with [the respondent], both in maintaining Yeni
safely in [the respondent’s] care and in supporting/nur-
turing [the respondent’s] relationship with Wendy. In
34
‘‘It is of no moment to the court’s reasonable efforts analysis that [the
department’s] efforts to engage with [the respondent] in August, 2022, were
not isolated to just Wendy and [the respondent], but also included services
and providers applicable to Yeni and [the respondent].’’
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addition to weekly supervised parent-child visitation,
[the department] has connected [the respondent] to
IRIS and to [IFP] services. [The department] has dili-
gently remained cognitive of the significant language
and cultural barriers attendant to the case and [the
department] has consistently worked around and
through both [Santos’ and the respondent’s] substantive
illiteracy and language fluency challenges. Additionally,
[the department] sought a court-ordered psychological
evaluation and parent-child interactional. Accordingly,
the court finds that [the department] made reasonable
efforts to reunify [the respondent] and Wendy.’’
(Emphasis in original; footnotes added; footnotes
altered; footnotes in original; footnotes omitted.)
With respect to whether the respondent was unable
or unwilling to benefit from the reunification efforts
made by the department, the court set forth the follow-
ing findings and conclusions: ‘‘[T]he court finds that
[the respondent] is unable to benefit from reunification
efforts. As noted previously, [the respondent] communi-
cated and/or virtually interacted with Wendy and [San-
tos] and with the foster family at least from 2019 to
the end of 2021.35 Although [the respondent’s] perhaps
culturally derived distrust of others (as testified to by
the IRIS worker) and her decision to attempt to immi-
grate to the United States and her journey to Connecti-
cut may have factored into [the respondent’s] 2022
incommunicado stance with [the department], that real-
ity rendered [the respondent] unable or unwilling to
benefit from reunification efforts.
‘‘The court is not indifferent to the fact that [the
respondent] and Yeni undertook an arduous and uncer-
tain journey to reunify with Wendy and [Santos] in
35
‘‘Although it is not clear, a careful review of [the testimony of the
respondent and Santos] suggests [that the respondent] participated in virtual
visits with Wendy during [Santos’] supervised visitation sessions beyond
the end of 2021.’’
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2022. Unfortunately, [the respondent’s] failure to timely
inform [the department] of her presence in New Haven,
and then her subsequent resistance to engage with pro-
viders until just recently, detrimentally delayed [the
respondent] in the opportunity [to] gain critical and
necessary knowledge and insight as to what constitutes
safe and nurturing parenting in an urban American
city.36
‘‘Inexplicably, [the respondent] does not endorse or
accept Wendy’s truth of being sexually assaulted by
Juan Carlos while in [Santos’] care in 2019. At the Janu-
ary, 2023 court-ordered parent-child interactional con-
ducted by [Schiappa], [the respondent] asked then nine
year old Wendy (a sexual assault victim) if she (Wendy)
had a boyfriend. To be sure she understood [the respon-
dent’s] question, Wendy asked [Schiappa] to translate
[the respondent’s] question into English. [Schiappa]
credibly testified [that] Wendy was shocked at [the
respondent’s] sincerely and seriously asked question.
[The respondent’s] boyfriend question is emblematic of
[the respondent’s] lack of insight into and appreciation
for Wendy’s past victimization. Until and unless [the
respondent was] to exhibit an ability to validate Wen-
dy’s traumas (physical abuse, sexual abuse, [Santos’]
neglect and failure to protect, removal from [Santos’]
care and entry into and protracted stay in foster care),
continued reunification efforts are of limited, if any,
value.
‘‘The court credits [Schiappa’s] testimony that, given
that [the respondent] had been living in New Haven
for only six months at the time of the January, 2023
psychological evaluations, perhaps [the respondent]
could benefit from additional time to gain insight and
understanding as to why Wendy had come into foster
36
‘‘To [the respondent’s] credit, she has recently start[ed] receiving posi-
tive parenting reports from her IFP worker.’’
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care, and why Wendy remained in foster care, and the
foreseeable challenges or issues for Wendy if she were
to leave her long-term foster [care] family and [return]
home to [the respondent’s] care. However, in the addi-
tional months since [Schiappa’s] evaluation, [the
respondent’s] lack [of] insight and understanding con-
tinues unabated. For all of those reasons, the court
finds that, in addition to [the department] having made
reasonable efforts to reunify [the respondent] and
Wendy, [the respondent] is unable or unwilling to bene-
fit from reunification efforts.’’ (Footnotes altered; foot-
note omitted.)
The court later set forth additional findings concern-
ing the respondent’s inability to benefit from the depart-
ment’s reunification efforts: ‘‘When asked what [the
respondent] needed to do for reunification to be possi-
ble, [Schiappa] credibly testified [that the respondent]
would need to (1) provide a sufficient and safe living
space for her and her children, (2) demonstrate insight,
knowledge and proficiency in safely caring for a nine
year old while also caring for a three year old, (3)
exhibit meaningful insight about how [the respondent’s]
decisions and behaviors have impacted Wendy, (4) be
accepting of Wendy’s truth regarding the sexual assault,
[and] (5) acknowledge the other traumatic events
Wendy has experienced and how said trauma(s) have
impacted Wendy and may continue to impact Wendy
in the future.’’
With respect to the respondent’s claim that the court
improperly determined, pursuant to § 17a-112 (j) (1),
that she was unable or unwilling to benefit from the
department’s efforts to reunify her and Wendy, we
observe that she does not challenge any of the court’s
specific subordinate findings as clearly erroneous.
Instead, the respondent broadly challenges the court’s
ultimate determination, which was based on those sub-
ordinate findings, that she was unwilling or unable to
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benefit from the department’s reunification efforts. She
asserts, contrary to the court’s assessment of her con-
duct, that the evidence demonstrated that, as of the
time of the trial, she had ‘‘positively engaged’’ with
the services that the department offered to her, which
included IRIS, a psychological evaluation, a substance
abuse evaluation, and parenting classes. The respon-
dent argues that, ‘‘[b]ecause the department did not
offer [her] necessary services toward reunification and
. . . [she] actively and appropriately engaged in the
services the department did offer her, the trial court
erred in determining [that she] was unable or unwilling
to benefit from services.’’
This court has observed that, pursuant to § 17a-112
(j) (1), ‘‘[t]he [petitioner] must prove [by clear and con-
vincing evidence] either that [the department] has made
reasonable efforts to reunify or, alternatively, that the
parent is unwilling or unable to benefit from the reunifi-
cation efforts. Section 17a-112 (j) clearly provides that
the [petitioner] is not required to prove both circum-
stances. Rather, either showing is sufficient to satisfy
this statutory element.’’ (Emphasis in original; internal
quotation marks omitted.) In re Corey C., 198 Conn.
App. 41, 66, 232 A.3d 1237, cert. denied, 335 Conn. 930,
236 A.3d 217 (2020).
‘‘[A]lthough it is true that a finding that the depart-
ment made reasonable reunification efforts is not a
necessary predicate to a finding that a parent is unable
to benefit from such efforts, this does not mean that a
trial court could never view those two issues as interre-
lated. . . . [T]he question of whether the [department]
made reasonable efforts to reunify the respondent with
her child is inextricably linked to the question of
whether the respondent can benefit from such efforts.
. . . Depending on the case, a trial court might well
conclude that the department’s reunification efforts
were so lacking as to preclude both a finding that the
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department made reasonable reunification efforts and
that a parent is unable to benefit from such efforts.
. . . However, the department is only required to prove
either that it has made reasonable efforts to reunify or,
alternatively, that the parent is unwilling or unable to
benefit from reunification efforts. Section 17a-112 (j)
clearly provides that the department is not required to
prove both circumstances. Rather, either showing is
sufficient to satisfy this statutory element.’’ (Citations
omitted; emphasis altered; internal quotation marks
omitted.) In re Cameron H., 219 Conn. App. 149, 161
n.5, 294 A.3d 50, cert. denied, 347 Conn. 903, 296 A.3d
171 (2023).
We review a trial court’s reunification determinations
for evidentiary sufficiency. See, e.g., In re Oreoluwa
O., 321 Conn. 523, 533, 139 A.3d 674 (2016); In re Kyreese
L., 220 Conn. App. 705, 716, 299 A.3d 296, cert. denied,
348 Conn. 901, 300 A.3d 1166 (2023). Pursuant to that
standard, ‘‘we consider whether the trial court could
have reasonably concluded, upon the facts established
and the reasonable inferences drawn therefrom, that
the cumulative effect of the evidence was sufficient to
justify its [ultimate conclusion]. . . . When applying
this standard, we construe the evidence in a manner
most favorable to sustaining the judgment of the trial
court. . . . We apply the identical standard of review
to a trial court’s determination that a parent is unable
to benefit from reunification services. . . . That is, we
review the trial court’s ultimate determination that a
respondent parent was unwilling or unable to benefit
from reunification services for evidentiary sufficiency,
and review the subordinate factual findings for clear
error. . . . [An appellate court does] not examine the
record to determine whether the trier of fact could have
reached a conclusion other than the one reached. . . .
[Rather] every reasonable presumption is made in favor
of the trial court’s ruling. . . .
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‘‘In our review of the record for evidentiary suffi-
ciency, we are mindful that, as a reviewing court, [w]e
cannot retry the facts or pass upon the credibility of
the witnesses. . . . Rather, [i]t is within the province
of the trial court, when sitting as the fact finder, to
weigh the evidence presented and determine the credi-
bility and effect to be given the evidence. . . . More-
over, it is within the province of the trier of fact to
accept or reject parts of the testimony of a single wit-
ness.’’ (Citations omitted; internal quotation marks
omitted.) In re Gabriella A., 319 Conn. 775, 789–90, 127
A.3d 948 (2015).
The respondent does not challenge the correctness
of any of the court’s subordinate factual findings con-
cerning the conduct of the department or the respon-
dent in the present case. Instead, the respondent chal-
lenges the court’s assessment of the degree to which
she was receptive to and utilized the services offered
as well as its ultimate determination that she was unable
or unwilling to benefit from the department’s services.
Among the court’s relevant subordinate findings was
that, although the respondent had access to a cell phone
while she was living in Guatemala, from mid-2019 to
December, 2021, she had only ‘‘limited and intermittent
contact’’ with the department. From December, 2021,
through August, 2022, the respondent did not respond
to communications, whether in the form of telephone
calls or texts, from the department. The respondent’s
failure to let the department know of her whereabouts
led to an inability of ISS-USA to conduct an updated
home study in 2022. The respondent did not make the
department aware of the fact that she intended to immi-
grate to the United States and did not contact the depart-
ment in a timely manner when she arrived in New Haven
on or about July 10, 2022. Rather, the respondent
appeared, unannounced, at a supervised visit between
Wendy and Santos in August, 2022.
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The court found that, for several months, the respon-
dent was very reluctant to engage with the services
the department offered through IRIS. This finding was
supported by the evidence that, although the depart-
ment referred the respondent to IRIS in September,
2022, an agreed upon home visit did not occur until
December, 2022. Moreover, the respondent did not fully
share information about her living situation with IRIS,
and it took until February, 2023, before IRIS workers
could develop a working relationship with her.
In August, 2022, the respondent participated in a sub-
stance abuse evaluation as well as parenting services
provided through IFP. The respondent also submitted
to court-ordered psychological evaluation and a parent-
child interactional study with Schiappa, a licensed psy-
chologist, in January, 2023. The court relied on the
detailed report prepared by Schiappa. Among her find-
ings was that ‘‘[the respondent] did not appear to under-
stand why Wendy couldn’t just be returned to her care
now that she is living in the United States. She does
not appear to understand the impact that her behaviors
have on her ability to safely parent the children.’’ Schi-
appa stated that the respondent did not come prepared
to the parent-child interactional study, as she had
brought her younger daughter, Yeni, but did not bring
anything with which to entertain her. She was indiffer-
ent to the fact that Yeni attempted to open a packet of
medicine from her purse and that the evaluator ulti-
mately had to intervene to prevent Yeni from ingesting
the medicine. Schiappa opined that ‘‘[the respondent]
does not appear to understand the differences in culture
or recognize how her behaviors are impacting her ability
to parent. [The respondent] minimizes any problems.
She was cooperative to the evaluation process but has
limited insight and judgment.’’ Schiappa also opined
that the respondent lacks ‘‘a good understanding of
Wendy’s needs or the capacity to meet them.’’ She stated
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that termination of the respondent’s parental rights
appears to be in Wendy’s best interest, that her biologi-
cal parents are unable to provide her with a stable and
safe home, and that, ‘‘[g]iven the amount of time that
has passed, it does not appear within an appropriate
time frame [that the respondent will be able] to provide
stability and permanency for Wendy.’’ Schiappa
observed that ‘‘[i]t would be impossible for [the respon-
dent or Santos] to be [Wendy’s] psychological parents
as neither of them have ever really provided the care
for her that a parent would. In Guatemala, [Wendy’s]
grandmother provided this care.’’
In its detailed findings, the court outlined the myriad
efforts to reunify that were made by the department
in this case despite the challenges posed by a global
pandemic and the danger presented by the fact that the
respondent was residing in Guatemala until July, 2022.
Mindful of the importance of reunification efforts made
by the department,37 we conclude that the department’s
reunification efforts were on their face not so lacking
as to preclude a finding that the respondent was unable
or unwilling to benefit from such services.38 The peti-
tioner did not prove by clear and convincing evidence
37
‘‘The requirement of reunification efforts provides . . . substantive pro-
tection for any parent who contests a termination action, and places a
concomitant burden on the state to take appropriate measures designed to
secure reunification of parent and child. . . . This requirement is based on
the well settled notion that [t]he right of a parent to raise his or her children
[is] recognized as a basic constitutional right.’’ (Citation omitted; emphasis
omitted; internal quotation marks omitted.) In re Devon B., 264 Conn. 572,
584, 825 A.2d 127 (2003).
38
Although it is unnecessary for us to reach the merits of the respondent’s
claim that the court improperly determined that the department made rea-
sonable efforts to reunify her with Wendy, we nonetheless observe that
‘‘[t]he reasonableness of the department’s efforts must be assessed in the
context of each case. The word reasonable is the linchpin on which the
department’s efforts in a particular set of circumstances are to be adjudged,
using the clear and convincing standard of proof. Neither the word reason-
able nor the word efforts is, however, defined by our legislature or by the
federal act from which the requirement was drawn. . . . [R]easonable
efforts means doing everything reasonable, not everything possible. . . .
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that the respondent failed to engage with all of the
department’s services, but such proof was not neces-
sary. The petitioner demonstrated by clear and convinc-
ing evidence, and the court found, that the respondent
had inconsistent communication with the department
when she was in Guatemala, she failed to timely notify
the department of her whereabouts prior to July, 2022,
and she was reluctant to engage in services offered by
the department until early 2023, which supported its
finding that the respondent was unwilling to benefit
from services offered by the department.
The respondent’s failure to timely engage in services
offered by the department detrimentally delayed her
ability to gain critical and necessary knowledge of how
Wendy’s needs changed upon her immigration to an
American city. The petitioner proved by clear and con-
vincing evidence, and the court found, that, at the time
of her evaluation by Schiappa, the respondent still dem-
onstrated a lack of insight into Wendy’s traumatic expe-
riences resulting from her relocation to the United
States, particularly her sexual abuse, and what was
required for her to provide Wendy a safe, nurturing, and
supportive environment free from insecurity. Affecting
her ability to benefit from services was the fact that
the respondent, who did not speak English and was
undocumented, required community based services to
meet even basic needs for food and shelter for herself
and Yeni. Her inability to converse in English with
Wendy was an obvious barrier to her being able to meet
Wendy’s psychological needs. The court also observed
that the respondent struggled to parent Yeni, showing
a lack of insight as to what was necessary to provide
[R]easonableness is an objective standard . . . and whether reasonable
efforts have been proven depends on the careful consideration of the circum-
stances of each individual case.’’ (Internal quotation marks omitted.) In re
Omar I., 197 Conn. App. 499, 589, 231 A.3d 1196, cert. denied, 335 Conn.
924, 233 A.3d 1091, cert. denied sub nom. Ammar I. v. Connecticut,
U.S. , 141 S. Ct. 956, 208 L. Ed. 2d 494 (2020).
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a safe environment for her, as well. The cumulative
effect of these findings supported the court’s ultimate
determination that the respondent, due in part to her
lack of understanding of what was required of her to
nurture Wendy and her struggles to have basic needs
met for herself and Yeni, was unable to benefit from
reunification efforts made by the department.
The judgment is affirmed.
In this opinion the other judges concurred.