Supreme Court of Connecticut

In re Annessa J. (Second Concurrence)

June 21, 2022

Summary

This concurrence joins the majority's conclusion that the termination of the respondents' parental rights after a virtual trial was proper and agrees that the Appellate Court incorrectly rejected the denial of posttermination visitation on the ground that the trial court used the wrong legal standard. The concurrence separately argues that the governing statute does not authorize courts to order posttermination visitation and that prior precedent recognizing such authority should be reconsidered. Because that precedent remains controlling, the concurrence proposes a heightened necessity standard and automatic termination of any visitation order upon adoption.