In re Jessica M
In In re Jessica M., 217 Conn. 459, 474-75, 586 A.2d 597 (1991) the respondent mother's visitation with the minor child and the child's memories or feelings for the mother were sufficient to preclude the termination of her parental rights on the alleged ground of lack of an ongoing parent-child relationship.
In In re Jessica M., 217 Conn. at 459, our Supreme Court defined an ongoing parent-child relationship as it applies to noncustodial parents.
The court stated that termination of a noncustodial parent's rights requires a finding that "the child has no present memories or feelings for the natural parent." 217 Conn. at 468.
Where the child does have present memories or feelings, there must be a finding that "no positive emotional aspects of the relationship survive." 217 Conn. at 470.