In Re Samantha S., 300 Conn. 586

In 2007, the commissioner of children and families petitioned to terminate the respondent father's parental rights to his minor child, Samantha S., after the mother had died and was withdrawn from the petition.
Before trial, father sought a declaratory ruling that DCF was obligated to pursue open adoptions that would permit continued contact with Samantha.
The parties entered a stipulated agreement: the father would consent to termination, and DCF would allow limited contact during the period the petitioner remained Samantha's statutory parent.
On May 14, 2008, the trial court canvassed the father's consent, found by clear and convincing evidence that termination was in the child's best interest, and terminated his rights with the petitioner as statutory parent.
Shortly after, the father learned of DCF's potential declaratory ruling and filed a motion to open the judgment under § 52-212a on May 20, 2008, based on that awareness.
The trial court denied the motion on July 23, 2008; the Appellate Court affirmed, concluding the record was inadequate to review the father's consent claim and the openness issue, and certiorari was granted to this court only to address the adequacy of the record; the Supreme Court dismissed the appeal as improvidently granted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the record adequate to review the father's consent/open-judgment claims?	Father contends the record sufficed for appellate review of lack of valid consent and open-judgment implications.	Petitioner contends the record is insufficient for review of those claims.	Appeal dismissed; certification improvidently granted; merits not reached.

In re Baby Girl B., 224 Conn. 263 (1992) (opening of judgments under § 52-212a requires consideration of best interests)
In re Samantha S., 120 Conn.App. 755 (2010) (affirmed inadequacy of record for review on appeal)