Conn. Gen. Stat. » Title 45a — PROBATE COURTS AND PROCEDURE · Chapter 803 — Termination of Parental Rights and Adoption
Connecticut General Statutes

Conn. Gen. Stat. § 45a-719 (2026)

Reopening judgment terminating parental rights. Best interest of child. Final decree of adoption

✓ current as of May 2026
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The court may grant a motion to open or set aside a judgment terminating parental rights pursuant to section 52-212 or 52-212a or pursuant to common law or may grant a petition for a new trial on the issue of the termination of parental rights, provided the court shall consider the best interest of the child, except that no such motion or petition may be granted if a final decree of adoption has been issued prior to the filing of any such motion or petition. Any person who has legal custody of the child or who has physical custody of the child pursuant to an agreement, including an agreement with the Department of Children and Families or a licensed child-placing agency, may provide evidence to the court concerning the best interest of the child at any hearing held on the motion to reopen or set aside a judgment terminating parental rights. For the purpose of this section, “best interest of the child” shall include, but not be limited to, a consideration of the age of the child, the nature of the relationship of the child with the caretaker of the child, the length of time the child has been in the custody of the caretaker, the nature of the relationship of the child with the birth parent, the length of time the child has been in the custody of the birth parent, any relationship that may exist between the child and siblings or other children in the caretaker's household, and the psychological and medical needs of the child. The determination of the best interest of the child shall not be based on a consideration of the socio-economic status of the birth parent or the caretaker.

(P.A. 93-91, S. 1, 2; 93-170, S. 1.)

History: P.A. 93-91 authorized substitution of commissioner and department of children and families for commissioner and department of children and youth services, effective July 1, 1993.

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Secs. 45a-720 to 45a-723. Reserved for future use.

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PART III*

ADOPTION

*Cited. 46 CA 69.

Cited. 45 CS 33.

Notes of Decisions
Cited in 14 cases (3 in the last 5 years), 2001–2025 · leading case: Kaddah v. Comm'r of Corr., 153 A.3d 1233 (Conn. 2017).
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Kaddah v. Comm'r of Corr., 153 A.3d 1233 (Conn. 2017). · cites it 5× “orpus petition not available remedy to challenge termination of parental rights because "permitting a habeas writ as a vehicle in which a parent whose rights have been terminated may attack that judgment collaterally, unbounded by constraints within which time such a petition…”
In re Jonathan M., 764 A.2d 739 (Conn. 2001). · cites it 5× “We agree with the department, however, that General Statutes § 45a-719 25 provides a number of alternatives *237 through which a parent may attempt to open the final judgment of termination and assert a claim of ineffective assistance of counsel.”
In Re Ilyssa G., 936 A.2d 674 (Conn. App. Ct. 2007). · cites it 6× “General Statutes § 45a-719. 4 The respondent met neither prong necessary for the court to open the judgment.”
In re Travis R., 838 A.2d 1000 (Conn. App. Ct. 2004). · cites it 7× “The respondent filed the motion to open the judgments pursuant to General Statutes § 45a-719, 3 alleging that she had provided consent to the termination under *781 duress.”
In Re Samantha S., 994 A.2d 259 (Conn. App. Ct. 2010). · cites it 6× “The respondent filed a motion to open the judgment terminating his parental rights on May 20, 2008; see General Statutes § 45a-719; 3 claiming that his consent *758 to that termination was not knowing because it was predicated on a mutual mistake.”
In Re Christopher G., 984 A.2d 1111 (Conn. App. Ct. 2009). · cites it 6× “On October 2, 2008, the respondent filed an amended motion to open or set aside the judgment of termination pursuant to General Statutes § 45a-719, alleging that her consent was the product of mutual a mistake.”
In Re Samantha S., 15 A.3d 1062 (Conn. 2011). · cites it 2× “3 Pursuant to General Statutes § 45a-719, “[t]he court may grant a motion to open or set aside a judgment terminating parental rights pursuant to section 52-212 or 52-212a or pursuant to common law .”
In re Zen T., 138 A.3d 469 (Conn. App. Ct. 2016). · cites it 9× “as required by General Statutes § 45a-719." (Footnotes omitted.”
In re Salvatore P., 812 A.2d 70 (Conn. App. Ct. 2002). · cites it 2× “With regard to that claim, we simply refer to General Statutes § 45a-719, which provides in relevant part: “The court may grant a motion to open or set aside a judgment terminating parental rights pursuant to section 52-212 or 52-212a or pursuant to common law or may grant a…”
In re J. D. (Conn. App. Ct. 2025). · cites it 6× “General Statutes § 45a-719 provides: ‘‘The court may grant a motion to open or set aside a judgment terminating parental rights pursuant to section 52-212 or 52-212a or pursuant to common law or may grant a petition for a new trial on the issue of the termination of parental…”
State v. Felimon C., 206 Conn. App. 727 (Conn. App. Ct. 2021). · cites it 3× “except that no such motion or petition may be granted if a final decree of adoption has been issued prior to the filing of any such motion or petition.”
In re Zen T. (Conn. App. Ct. 2014). · cites it 4× “General Statutes § 45a-719.’’ (Internal quotation marks omitted.”
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