In re Sarah Ann K
In In re Sarah Ann K., 57 Conn. App. 441, 749 A.2d 77 (2000) the Court addressed a similar issue. In that case, the child was adjudicated neglected in 1995. One year later, the commissioner filed a petition to terminate the respondent's parental rights.
Finding that the department had failed to make reasonable efforts to reunify the respondent with his child, the trial court declined to terminate the respondent's parental rights and ordered specific expectations for the respondent to fulfill. In 1998, after the commissioner filed a second termination petition, the trial court terminated the respondent's parental rights to his child on the ground that the respondent had failed to achieve such a degree of personal rehabilitation as would encourage the belief that within a reasonable time, considering the age and needs of the child, the respondent could assume a responsible position in the life of the child.
On appeal, the respondent in In re Sarah Ann K. claimed that the trial court improperly terminated his parental rights because he was not provided with specific steps to facilitate the return of his child. Concluding that the trial court in fact had provided the respondent with specific steps, we stated that "specific steps the parent may take to facilitate the return of the child were required to have been provided to the respondent in the prior neglect proceeding pursuant to General Statutes (Rev. to 1997) 46b-129 (b). . . . That statute, however, does not require that the parent again be provided specific steps to take to facilitate the return of the child before a termination petition may be granted." In re Sarah Ann K., supra, 57 Conn. App. 445.