The panel reviewed a termination order in a contested care‑and‑protection matter in which an incarcerated father argues the Department of Children and Families (DCF) did not make reasonable efforts to engage him while he was housed out of state.

Counsel for the father recounted efforts the father says he made while incarcerated — completion of substance‑abuse and parenting programs, enrollment in college, and repeated letters to the department and court investigator — and argued that DCF's social worker made only minimal outreach and therefore the court's best‑interest analysis improperly discounted contact and progress he claims to have achieved. "All of that time, father was incarcerated in New York State," counsel said. "He did what he could on his own, and the department was aware that he was incarcerated in New York."

The Department's counsel and the child's advocate countered that the father did not timely assert an inadequate‑efforts claim before the termination proceeding or produce documentation of claimed programs, visitation requests, or a concrete post‑release parenting plan. DCF told the court it repeatedly attempted to contact prison officials and used available avenues (sending action plans, asking mother to relay messages) and that many of the father's broader history factors — substance abuse, homelessness, domestic‑violence incidents, and prior periods of non‑engagement — supported the trial court's conclusion that termination was in the child's best interest.

The court questioned whether the reasonable‑efforts issue had been waived by timing and whether the record contained sufficient proof of the father's claimed in‑custody steps. The child’s counsel emphasized the child's need for stability and the limited meaningful bond between child and father, noting that the child referred to the mother's partner as "daddy" at trial. The panel took the matter under advisement.