The mission of the Connecticut Judicial Branch is to serve the interests of justice and the public by resolving matters brought before it in a fair, timely, efficient and open manner.

Juvenile Law Supreme Court Opinion

by Booth, George


SC20245 - In re Teagan K.-O. ("This case requires us to consider whether a Connecticut trial court has subject matter jurisdiction over a petition to adjudicate a newborn child neglected on the basis of "predictive neglect" when the parents relocated to another state shortly before the child's birth, purportedly with no intention of returning, and that state determined that Connecticut would be a more convenient forum to adjudicate this matter. The respondent father appeals from the trial court's decision denying his motion to dismiss the petition filed by the petitioner, the Commissioner of Children and Families, to adjudicate the respondents' child, Teagan K.-O., neglected. The father contends that, irrespective of the fact that a petition to terminate the respondents' parental rights with respect to another child of theirs was pending in Connecticut when they relocated to Florida, a Connecticut trial court cannot exercise subject matter jurisdiction over Teagan's neglect petition because any neglect of her would never occur in this state. The commissioner contends that the determination by a Florida court that this state would be a more appropriate forum provided a proper basis for the Connecticut trial court's subject matter jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), which has been adopted by both states. See General Statutes §§ 46b-115 through 46b-115gg; Fla. Stat. Ann. § 61.501 et seq. (West 2012). We agree with the father's jurisdictional argument. The trial court, therefore, improperly denied his motion to dismiss the neglect petition.")