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Adoption subsidy
denial to parent of special needs child affirmed. The Court found
that because the record did not indicate that the Probate Court
determined that Jonathan had been 'placed' by Jewish Family Service
rather than by Americans for International Aid and Adoption, that
the doctrine of collateral estoppel did not preclude the Adoption
Subsidy Review Board from litigating which agency had in fact 'placed'
Jonathan for adoption. Secondly, the Court construed the term 'placed'
in Connecticut General Statutes § 17a-116 to mean the process by
which physical custody of a child is transferred to prospective
adoptive parents, and it does not refer to the process by which
a child is given in adoption by a statutory parent. The Court did
not reach the constitutional issues.
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