In re Heather L.

Summary

The Connecticut Supreme Court affirmed the termination of J's parental rights concerning two children. The court held that the trial judge's prior participation in a related termination proceeding, without a showing of bias or prejudice, did not require disqualification, and that the respondent's motion for mistrial and sanctions was properly denied.

Holdings

1. A judge's familiarity with a party's personal history resulting from participation in a prior proceeding, standing alone and without a showing of bias, does not require disqualification.
2. The record did not demonstrate that the trial judge was biased against the respondent based on his prior knowledge of reports or other information from the related proceeding.

Questions Presented

1. Whether the respondent's motion for mistrial and sanctions should have been construed as a motion to disqualify the trial judge.
2. Whether the trial judge was required to disqualify himself merely because he had presided over a prior related proceeding and thereby acquired familiarity with the respondent's personal history and certain evidence.
3. Whether the trial judge's prior knowledge of reports and facts from the related proceeding demonstrated bias or prejudice against the respondent.

Disposition

affirmed