In re Elvin G.
Annotate this CaseFather's parental rights to his two minor children were terminated based on the trial court's determination that Father failed to rehabilitate. Father appealed, arguing that the trial court improperly terminated his parental rights because court-ordered specific steps were statutorily required as a prerequisite to termination for failure to rehabilitate and the Commissioner of Children and Families did not provide him with such steps. The Supreme Court affirmed, holding (1) the trial court's conclusion that the prior provision of specific steps is not required in termination proceedings for failure to rehabilitate was legally incorrect; but (2) under the particular circumstances of this case, the failure to provide specific steps was harmless error.
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