In re Jewelyette M., SC21227

After the child was adjudicated neglected and committed to the commissioner, the mother’s parental rights were terminated and the child was placed with the foster parents while the father was incarcerated. 1
The commissioner later sought to remove the child from the foster parents and place her with paternal relatives, and the foster parents intervened to oppose that plan and the father’s revocation motion. 2
This court previously held that the foster parents had been improperly removed as intervenors and remanded for further proceedings. 3
On remand, the trial court appointed the commissioner as statutory parent without objection, and the foster parents later filed a timely motion to open that appointment based on counsel’s mistake. 4
Before the trial court heard the motion to open, it granted the commissioner’s adoption petition for the child’s paternal aunt and uncle. 5
The trial court then denied the motion to open as moot because the adoption had already occurred. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must the trial court hear the timely motion to open before adoption? 7	Foster parents: timely motion to open had to be decided before adoption.	Commissioner: adoption made the motion moot or unnecessary.	Yes; the court had to hear and decide the motion before adoption. 8
Did the trial court improperly treat the motion as moot? 9	Foster parents: proceeding with adoption effectively refused to consider the motion.	Commissioner: court managed its docket and later heard the motion.	Yes; the court’s handling was tantamount to refusing to consider it. 10
What remedy follows from the error? 11	Foster parents: denial should be reversed and remanded for merits hearing.	Commissioner: no practical relief after adoption.	Reversed and remanded for a merits hearing including best-interest analysis. 12

In re Jewelyette M., 351 Conn. 511 (Conn. 2025) (prior appeal restoring foster parents’ intervenor status 13)
In re Ryan C., 220 Conn. App. 507 (Conn. App. 2023) (later overruled interpretation of permissive intervention in neglect proceedings 14)
Ahneman v. Ahneman, 243 Conn. 471 (Conn. 1998) (trial courts must decide properly presented motions 15)
Ramin v. Ramin, 281 Conn. 324 (Conn. 2007) (court lacks authority to refuse to consider motions absent extreme circumstances 16)
Hamilton v. Hamilton, 354 Conn. 639 (Conn. 2026) (trial court may not decline jurisdiction for judicial efficiency 17)
Hallock v. Hallock, 228 Conn. App. 81 (Conn. App. 2024) (docket management does not excuse failure to decide motions 18)
In re P. T.-W., 223 Conn. App. 571 (Conn. App. 2024) (motion to open should be heard before adoption is finalized 19)
In re Baby Girl B., 224 Conn. 263 (Conn. 1992) (section 52-212a is remedial and fairness oriented 20)
Argent Mortgage Co., LLC v. Huertas, 288 Conn. 568 (Conn. 2008) (a moot motion should be dismissed rather than denied 21)