Asia A.M. v. Geoffrey M., 182 Conn. App. 22

In April 2011 Geoffrey M., Jr. and Asia A. M. signed a written acknowledgment of paternity for a child; an acknowledgment has the force of a Superior Court judgment and contains a 60‑day rescission window.
More than three years later the state filed a support petition and Geoffrey moved to open the acknowledgment, alleging fraud, mistake of fact (DNA showing 0% paternity), and duress, and asserting it was in the child’s best interests to establish the biological father.
A family support magistrate found no fraud, duress, or mistake of fact but granted the motion to open the acknowledgment solely on the “best interests of the child” rationale and ordered nonpaternity and dismissal of the support petition.
The state appealed; the trial court affirmed in part, holding that Ragin v. Lee created a nonstatutory “fourth ground” (best interests) to open paternity judgments and that the magistrate had inherent authority to do so, but remanded for further best‑interest factfinding.
The Appellate Court reversed, holding that § 46b‑172(a)(2) limits post‑rescission challenges to fraud, duress, or material mistake of fact and that neither Ragin nor magistrates’ inherent authority permits opening acknowledgments based solely on child‑best‑interests.

Issue	Plaintiff's Argument	Defendant's (State's) Argument	Held
Whether Ragin v. Lee created a nonstatutory "fourth ground" (best interests) to open an acknowledgment of paternity	Rely on Ragin: best interests of the child can justify opening a paternity judgment absent statutory grounds	Ragin did not create such a ground; statute §46b‑172(a)(2) limits post‑rescission challenges to fraud, duress, or material mistake	Held for State: Ragin did not create an independent best‑interests ground; courts cannot add to clear statutory grounds
Whether a family support magistrate has inherent authority to open an acknowledgment on best‑interests grounds	Magistrate may use inherent power/good cause to open a judgment when child’s best interests require it	Family support magistrates are creatures of statute and only have powers conferred by statute; §46b‑172(a)(2) circumscribes authority	Held for State: magistrates lack inherent authority to contravene §46b‑172(a)(2); cannot open acknowledgment solely on best interests
Whether fraud on the state/child/biological father justified opening (raised on appeal)	Plaintiff and guardian ad litem argued parties committed broader fraud warranting opening	State/record: those broader fraud claims were not raised/tried below and thus are not before the appellate court	Appellate Court declined to address unpreserved fraud claims; appellate courts do not make factual findings

Ragin v. Lee, 78 Conn. App. 848, 829 A.2d 93 (Conn. App. 2003) (discusses child’s independent interest in accurate paternity determinations; did not create a statutory exception for best‑interests reopening)
McCullough v. Swan Engraving, Inc., 320 Conn. 299, 130 A.3d 231 (Conn. 2016) (courts must construe statutes as written and may not add exceptions)
Pritchard v. Pritchard, 103 Conn. App. 276, 928 A.2d 566 (Conn. App. 2007) (statutory construction and magistrate authority principles)
Jonas v. Playhouse Square Condominium Assn., Inc., 173 Conn. App. 36, 161 A.3d 1288 (Conn. App. 2017) (inherent authority to open or modify judgments is restricted by statute and practice rules)
Cornfield Associates Ltd. Partnership v. Cummings, 148 Conn. App. 70, 84 A.3d 929 (Conn. App. 2014) (same principle limiting inherent judicial powers)
Palomba v. Gray, 208 Conn. 21, 543 A.2d 1331 (Conn. 1988) (recognizes importance of genetic testing and accuracy in paternity adjudications)