In re Ebony H
In re Ebony H., 68 Conn. App. 342, 789 A.2d 1158 (Conn. App. 2002), stands in contrast to the instant case. There, the mother, an abuser of cocaine, was referred to several substance abuse programs, as well as counseling sessions, for which she failed to keep appointments. Id. at 1161.
Eventually, the mother completed a forty-five day inpatient substance abuse program, and then asked the department to assist her in obtaining housing. "In response, the department 'did nothing more than make one telephone call to Community Action with no follow up.'" Id.
Nine days later, the mother again tested positive for cocaine, and missed several subsequent appointments for enrollment into other substance abuse programs. Id. at 1161-62.
Although the trial court castigated the department for its response to the mother's request for housing assistance, calling it "'shameful and far beneath any acceptable level of professional conduct,'" id. at 1162 (quoting trial court), the trial court ultimately concluded that the department had made reasonable efforts toward reunification, given the multiple referrals for substance abuse treatment, and that "'cocaine addiction and a failure to follow through on counseling are the factors that prohibit reunification. . . .'" Id. (quoting trial court). The appellate court affirmed, stating, id. at 1163:
Notwithstanding the court's finding that the department's response to the mother's request for assistance in obtaining housing was shameful and unacceptable, our review of the evidence. . .does not leave us with a definite and firm conviction that the court mistakenly found that the department had made reasonable efforts. . . . The evidence overwhelmingly supports the court's findings that the department, on numerous occasions, had enrolled the mother in treatment programs. . . and that her addiction. . .thwarted the department's efforts to reunify her and the child.