Connecticut General Statutes

Conn. Gen. Stat. § 45a-644 (2026)

(Formerly Sec. 45-70a). Definitions

✓ current as of May 2026

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For the purposes of this section and sections 45a-645 to 45a-663, inclusive, the following terms shall have the following meanings:

(a) “Conservator of the estate” means a person, municipal or state official, corporation, limited liability company, partnership or other entity recognized under the laws of this state, whether or not operated for profit, except a hospital, nursing home facility, as defined in section 19a-521, or residential care home, as defined in section 19a-521, appointed by the Probate Court under the provisions of this section and sections 45a-645 to 45a-663, inclusive, to supervise the financial affairs of a person found to be incapable of managing his or her own affairs or of a person who voluntarily asks the Probate Court for the appointment of a conservator of the estate, and includes a temporary conservator of the estate appointed under the provisions of section 45a-654.

(b) “Conservator of the person” means a person, municipal or state official, corporation, limited liability company, partnership or other entity recognized under the laws of this state, whether or not operated for profit, except a hospital or nursing home facility as defined in section 19a-521, appointed by the Probate Court under the provisions of this section and sections 45a-645 to 45a-663, inclusive, to supervise the personal affairs of a person found to be incapable of caring for himself or herself or of a person who voluntarily asks the Probate Court for the appointment of a conservator of the person, and includes a temporary conservator of the person appointed under the provisions of section 45a-654.

(c) “Incapable of caring for one's self” or “incapable of caring for himself or herself” means that a person has a mental, emotional or physical condition that results in such person being unable to receive and evaluate information or make or communicate decisions to such an extent that the person is unable, even with appropriate assistance, to meet essential requirements for personal needs.

(d) “Incapable of managing his or her affairs” means that a person has a mental, emotional or physical condition that results in such person being unable to receive and evaluate information or make or communicate decisions to such an extent that the person is unable, even with appropriate assistance, to perform the functions inherent in managing his or her affairs, and the person has property that will be wasted or dissipated unless adequate property management is provided, or that funds are needed for the support, care or welfare of the person or those entitled to be supported by the person and that the person is unable to take the necessary steps to obtain or provide funds needed for the support, care or welfare of the person or those entitled to be supported by the person.

(e) “Involuntary representation” means the appointment of a conservator of the person or a conservator of the estate, or both, after a finding by the Probate Court that the respondent is incapable of managing his or her affairs or incapable of caring for himself or herself.

(f) “Respondent” means an adult person for whom an application for involuntary representation has been filed or an adult person who has requested voluntary representation.

(g) “Voluntary representation” means the appointment of a conservator of the person or a conservator of the estate, or both, upon request of the respondent, without a finding that the respondent is incapable of managing his or her affairs or incapable of caring for himself or herself.

(h) “Conserved person” means a person for whom involuntary representation is granted under this section and sections 45a-645 to 45a-663, inclusive.

(i) “Personal needs” means the needs of a person including, but not limited to, the need for food, clothing, shelter, health care and safety.

(j) “Property management” means actions to (1) obtain, administer, manage, protect and dispose of real and personal property, intangible property, business property, benefits and income, and (2) deal with financial affairs.

(k) “Least restrictive means of intervention” means intervention for a conserved person that is sufficient to provide, within the resources available to the conserved person either from the conserved person's own estate or from private or public assistance, for a conserved person's personal needs or property management while affording the conserved person the greatest amount of independence and self-determination.

(P.A. 77-446, S. 1; P.A. 80-476, S. 123; P.A. 84-271, S. 1; P.A. 93-184; P.A. 05-154, S. 2; P.A. 07-116, S. 10; P.A. 12-22, S. 24; P.A. 13-208, S. 58; P.A. 16-7, S. 8.)

History: P.A. 80-476 reordered Subdivs. to place terms in alphabetical order; P.A. 84-271 amended the definitions of “conservator of the estate” and “conservator of the person” to include a “municipal” official, deleting the requirement that a state official be “legally authorized”, and to include a temporary conservator appointed under Sec. 45-72; Sec. 45-70a transferred to Sec. 45a-644 in 1991; P.A. 93-184 amended Subsecs. (c) and (d) by deleting references to “advanced age”; P.A. 05-154 amended Subsec. (c) to define “incapable of caring for himself or herself”; P.A. 07-116 substituted “45a-663” for “45a-662”, redefined “incapable of caring for one's self” and “incapable of managing his or her affairs”, substituted “conserved person” for “ward”, defined “personal needs”, “property management” and “least restrictive means of intervention”, and made technical changes; P.A. 12-22 changed “nursing home” to “nursing home facility” in Subsecs. (a) and (b); P.A. 13-208 redefined “conservator of the estate” by adding reference to residential care home and making a technical change, effective July 1, 2013; P.A. 16-7 redefined “conservator of the estate”, redefined “conservator of the person” and made technical changes.

Annotation to former section 45-70a:

Cited. 199 C. 524.

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Notes of Decisions

Cited in 25 cases (4 in the last 5 years), 1995–2025 · leading case: Day v. Seblatnigg, 199 A.3d 1103 (Conn. App. Ct. 2018).

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Day v. Seblatnigg, 199 A.3d 1103 (Conn. App. Ct. 2018). · cites it 8× “" "Property management" is defined in General Statutes § 45a-644 (j) as "actions to (1) obtain, administer, manage, protect and dispose of real and personal property, intangible property, business property, benefits and income, and (2) deal with financial affairs.”

Falvey v. ZUROLO, 22 A.3d 682 (Conn. App. Ct. 2011). · cites it 10× “[15] General Statutes § 45a-644 (k) provides: "`Least restrictive means of intervention' means intervention for a conserved person that is sufficient to provide, within the resources available to the conserved person either from the conserved person's own estate or from private…”

Luster v. Luster, 17 A.3d 1068 (Conn. App. Ct. 2011). · cites it 6× “NOTES [1] General Statutes § 45a-644 defines conserved person as "a person for whom involuntary representation is granted under sections 45a-644 to 45a-663, inclusive.”

Wiseman v. Armstrong, 850 A.2d 114 (Conn. 2004). · cites it 2× “Under those statutes, before the aforementioned rights may be denied to an individual involuntarily, the court must set a hearing and give the subject individual notice of, inter alia, the time and place of the hearing, the facts alleged in the application for involuntary…”

State v. Garcia, 658 A.2d 947 (Conn. 1995). · cites it 2× “See General Statutes §§ 45a-644 to 45a-663 and 17a-543 (requiring consent of conservator of person).”

Off. of Prot. & Advocacy for Persons With Disabilities v. Armstrong, 266 F. Supp. 2d 303 (D. Conn. 2003). · cites it 2× “Moreover, it is clear under Connecticut law that the deceased inmates in question could not have had a conservator or legal guardian.”

Barbara C. Ehrlich v. Town of Glastonbury, Joel White, James Kenny, 348 F.3d 48 (2d Cir. 2003). “See also Conn. Gen.Stat. §§ 45a-644, 655 & 656 (detailing rights and duties of conservators).”

Rzayeva v. United States, 492 F. Supp. 2d 60 (D. Conn. 2007). “(providing for guardians) and §§ 45a-644 et seq. (providing for conservators), nor does it help Plaintiffs’ argument.”

State v. Lavigne, 995 A.2d 94 (Conn. App. Ct. 2010). · cites it 2× “appointed by the Court of Probate under the provisions of sections 45a-644 to 45a-663, inclusive, to supervise the financial affairs of a person found to be incapable of managing his or her own affairs .”

Dep't of Soc. Servs. v. Saunders, 724 A.2d 1093 (Conn. 1999). “General Statutes § 45-70a (a) [now § 45a-644 (a)].” (Citations omitted; internal quotation marks omitted.”

Kindred Nursing Centers East, LLC v. Morin, 7 A.3d 919 (Conn. App. Ct. 2010). · cites it 2× “See General Statutes § 45a-644. In an area of the law as comprehensively codified as that of conservatorship, we decline to impute to the legislature an intent to impose the same duties on an attorney in fact as the law now imposes on a conservator.”

Ross Ex Rel. Ross v. Rell, 392 F. Supp. 2d 224 (D. Conn. 2005). · cites it 2× “” That rule would seem to implicate Conn. Gen.Stat. § 45a-644(b) — (c). which allows the probate court to appoint a temporary or permanent conservator when a person is “found to be incapable of caring for himself,” further defined as suffering from “a mental, emotional, or…”

Show all 25 citing cases →

— Conn. Gen. Stat. § 45a-644(a) — 1 case

Ressler v. Harrington (In re Gold), 533 B.R. 851 (D. Conn. 2015).

— Conn. Gen. Stat. § 45a-644(b) — 2 cases

Off. of Prot. & Advocacy for Persons With Disabilities v. Armstrong, 266 F. Supp. 2d 303 (D. Conn. 2003). “Moreover, it is clear under Connecticut law that the deceased inmates in question could not have had a conservator or legal guardian.”

Ross Ex Rel. Ross v. Rell, 392 F. Supp. 2d 224 (D. Conn. 2005). “” That rule would seem to implicate Conn. Gen.Stat. § 45a-644(b) — (c). which allows the probate court to appoint a temporary or permanent conservator when a person is “found to be incapable of caring for himself,” further defined as suffering from “a mental, emotional, or…”

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