Supreme Court of Connecticut

In re Tresin J.

December 31, 2019334 Conn. 314

Summary

The court affirmed the termination of the father's parental rights based on clear and convincing evidence that no ongoing parent-child relationship existed. It held that the virtual-infancy exception is assessed based on the child's age and ability to express present feelings at the termination hearing, and that the interference exception requires conduct by the petitioner that inevitably caused the lack of relationship. The court concluded that neither exception applied because the child was six years old, had no positive memories of the father, and the initial separation resulted from incarceration and circumstances involving the custodial parent rather than petitioner conduct.