Supreme Court of Connecticut

In Re Oreoluwa O.

May 31, 2016321 Conn. 523

Summary

The court held that the Department of Children and Families failed to prove by clear and convincing evidence that it had made reasonable efforts to reunify the respondent father with his child before seeking termination of parental rights. The department relied on the father's inability to travel to Connecticut without obtaining updated medical information about when the child might travel to Nigeria or investigating available medical care there. The court reversed the Appellate Court and remanded for reversal of the termination judgment and further proceedings. ESPINOSA, J., dissenting, would have upheld the termination because the record and reasonable inferences supported the trial court's finding that the department made reasonable reunification efforts.