In re Yasiel R.
Annotate this CaseAfter a hearing, the trial court terminated the parental rights of Mother as to her two minor children. Mother appealed, arguing that the trial court violated her right to due process when it failed to canvass her about her decision to waive her right to a full trial and to not contest the prosecution’s exhibits. The Appellate Court affirmed, concluding that Mother’s constitutional claim failed under the third prong of State v. Golding. Specifically, the Court concluded that, in order to prevail on an unpreserved claim under Golding, which requires that a party establish that an alleged constitutional violation “clearly exists,” a party must point to binding Connecticut precedent. The Supreme Court reversed, holding (1) the absence of existing Connecticut precedent does not preclude consideration of a claim under Golding; (2) the trial court’s failure to canvass Mother did not constitute a denial of her right to due process; but (3) the Court is warranted in using its supervisory authority over the administration of justice to impose a canvass rule requiring that a trial court canvass all parents who do not consent to the termination immediately before a parental rights termination trial, in order to ensure the overall fairness of the termination of parental rights process.
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