In re Ricari B.

── In re Ricari B. ── Court: Connecticut Appellate Court Date: May 20, 2026 Author: Cradle Category: General ************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************  In re Ricari B. IN RE RICARI B.* (AC 49119) Cradle, C. J., and Alvord and Seeley, Js. Syllabus The respondent father appealed from the trial court’s judgment terminating his parental rights with respect to his minor child. The father claimed that the court improperly determined that he was unable or unwilling to benefit from the reunification efforts of the Department of Children and Families. Held: The respondent father’s appeal was not moot, despite the claim of the peti- tioner, the Commissioner of Children and Families, that the father had challenged only one of the two bases for the trial court’s determination that the statutory (§ 17a-112 (j) (1)) requirements for the termination of parental rights had been satisfied, as the court did not make a finding by clear and convincing evidence that the department had made reasonable efforts to reunify the respondent with the child. This court concluded that the trial court’s determination that the respondent father was unable or unwilling to benefit from the department’s reunifica- tion efforts was supported by sufficient evidence, including evidence that the father had refused to communicate with the department for a five month period, that he had failed to benefit from counseling and substance abuse services, that he had tested positive for substances on numerous occasions, that he was inconsistent in complying with substance use tests, and that he had acted aggressively with probation staff, treatment providers, and department staff. Argued April 29—officially released May 20, 2026** Procedural History Petition by the Commissioner of Children and Fami- lies to terminate the respondents’ parental rights with respect to their minor child, brought to the Superior * In accordance with the spirit and intent of General Statutes § 46b- 142 (b) and Practice Book § 79a-12, the names of the parties involved in this appeal are not disclosed. The records and papers of this case shall be open for inspection only to persons having a proper interest therein and upon order of the court. Moreover, in accordance with federal law; see 18 U.S.C. § 2265 (d) (3) (2024); we decline to identify any person protected or sought to be protected under a protection order, protective order, or a restraining order that was issued or applied for, or others through whom that person’s identity may be ascertained. ** May 20, 2026, the date that this de