Terminating Father's Parental Rights In Connecticut
In regard to the failure to achieve personal rehabilitation, General Statutes (Rev. to 1997) 17a-112 (c) (3) (B) provides for the termination of parental rights when:
"the parent of a child who has been found by the Superior Court to have been neglected or uncared for in a prior proceeding has failed to achieve such degree of personal rehabilitation as would encourage the belief that within a reasonable time, considering the age and needs of the child, such parent could assume a responsible position in the life of the child . . . ."
"Personal rehabilitation as used in the statute refers to the restoration of a parent to his or her former constructive and useful role as a parent. . . . Section 17a-112 requires the trial court to analyze the parent's rehabilitative status as it relates to the needs of the particular child, and further, that such rehabilitation must be foreseeable within a reasonable time. . . . the statute requires the court to find, by clear and convincing evidence, that the level of rehabilitation he has achieved, if any, falls short of that which would reasonably encourage a belief that at some future date he can assume a responsible position in his child's life." In re Eden F., supra, 250 Conn. 706.
"This court recently explained that in assessing rehabilitation, the critical issue is not whether the parent has improved his ability to manage his own life, but rather whether he has gained the ability to care for the particular needs of the child at issue." In re Shyliesh H., supra, 56 Conn. App. 180.