In re Christopher G

Connecticut Appellate Court

December 22, 2009

TERMINATION OF PARENTAL RIGHTS/CONSENT/OPEN ADOPTION

The main issue in this appeal was the trial court’s denial of the mother’s motion to open a judgment of voluntary termination of her parental rights. The mother contended that judgment should have been vacated because the mother’s consent was contingent on the child being adopted by relative foster parents and the open adoption agreement between the relatives and the mother, and the child was ultimately adopted by another couple after the termination proceeding concluded. The trial court allowed the mother’s motion to be heard and accepted legal briefs on the issues involved. The court concluded, and the appellate court affirmed, that the mother had been adequately canvassed during the termination proceeding, and that the record demonstrated that the mother was aware that the adoption by proposed relatives was not guaranteed and that an open adoption agreement was not enforceable by the juvenile court.

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