SC21078, SC21079 - In re Andrew C. ("Under General Statutes § 52-212a, courts lack the power to open a judgment unless a motion to open is filed within four months of the date that notice of the judgment was issued. One exception to this rule is when the trial court’s lack of subject matter jurisdiction was entirely obvious at the time of the judgment. See, e.g., Schoenhorn v. Moss, 347 Conn. 501, 515, 298 A.3d 236 (2023). The dispositive issue in these certified appeals is whether the Appellate Court correctly determined that the trial court lacked subject matter jurisdiction to grant a motion by foster parents for permissive intervention in the dispositional phase of a neglect proceeding. In 2023, the respondent father, Chester C. (respondent), filed a motion to open and vacate a 2021 judgment transferring guardianship of his minor son, Andrew C. (Andrew), to the intervening foster parents, Morgan A. and Alberto A. The motion was filed on the basis of In re Ryan C., 220 Conn. App. 507, 299 A.3d 308, cert. denied, 348 Conn. 901, 300 A.3d 1166 (2023), in which the Appellate Court held that General Statutes § 46b-129 (p) prohibits foster parents from intervening in such proceedings. Id., 525–26. The trial court granted the respondent’s motion and vacated the judgment transferring guardianship. The court reasoned that, because the foster parents were statutorily prohibited from intervening, the trial court lacked jurisdiction to grant their motion to intervene, and, therefore, the resulting judgment transferring guardianship of Andrew to them was void ab initio. The Appellate Court upheld the trial court’s decision on the respondent’s motion; In re Andrew C., 229 Conn. App. 51, 71, 326 A.3d 575 (2024); and we granted Andrew’s and the foster parents’ separate petitions for certification to appeal. While their appeals were pending, this court decided In re Jewelyette M., 351 Conn. 511, 332 A3d 207 (2025), which overruled In re Ryan C., concluding that ‘‘the legislature did not intend § 46b-129 (p) to prohibit a trial court from granting permissive intervention to a foster parent when appropriate.’’ Id., 515. Our decision in In re Jewelyette M., which held that § 46b-129 (p) does not limit the trial court’s authority to permit a foster parent to intervene in accordance with Practice Book § 35a-4 (c); id., 535; controls the outcome of these appeals, and, accordingly, we reverse the Appellate Court’s judgment.")

AC47971 - In re J. D. ("The respondent mother, A. T., appeals from the judgment of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating her parental rights and denying her motion for posttermination visitation rights with respect to her daughter, J. On appeal, the respondent claims that she did not receive effective assistance of counsel in opposing the petition to terminate her parental rights because her trial counsel did not present the testimony of Ralph Balducci, a psychologist, who had evaluated the respondent in January, 2023. We conclude that the respondent has not presented an adequate record by which we can review that claim and, accordingly, affirm the judgment of the court.")