Connecticut Paternity / Parentage Petition Packet

Connecticut Paternity / Parentage Petition Packet

Part 1. Pre-Petition Checklist

☐ Confirm standing to maintain the proceeding under C.G.S. § 46b-458 (child through a representative, the person who gave birth, an alleged/adjudicated/presumed/intended/de facto parent, the state or other authorized entity)
☐ Confirm venue under C.G.S. § 46b-461: generally the judicial district where the person who gave birth or the alleged parent resides (IV-D cases: Family Support Magistrate Division serving that district)
☐ Determine forum: Superior Court vs. Family Support Magistrate Division (for Title IV-D cases — C.G.S. § 46b-231)
☐ Verify child's age (a proceeding may generally be brought before the child's 18th birthday; past-due support is limited to the three years next preceding the filing — C.G.S. § 46b-569(a)(3))
☐ Determine whether an Acknowledgment of Parentage (AOP; historically the PA-1 Acknowledgment of Paternity) has been signed and filed in the DPH parentage registry (C.G.S. § 7-50; § 19a-42a)
☐ If an AOP has been filed, calculate the rescission window under C.G.S. § 46b-482 (earlier of 60 days after the effective date, or the first hearing in a proceeding about the child)
☐ Determine whether a presumption of parentage applies under C.G.S. § 46b-488 (marriage; birth within 300 days of a terminated marriage; holding out for two years) — a presumed parent may need to be joined or the presumption adjudicated under § 46b-489
☐ If a IV-D case or the child receives/received state aid, confirm the Attorney General's party status (C.G.S. §§ 46b-231, 46b-562, 46b-571)
☐ ICWA inquiry under 25 U.S.C. § 1903
☐ Gather identifying information for all parties (DOB, SSN, addresses)
☐ Obtain certified copy of Connecticut Birth Certificate
☐ Prepare the current Judicial Branch parentage Petition/Application, Summons, and Order (verify the current form number on the Judicial Branch Family Matters forms site)
☐ Prepare proposed Order for Genetic Testing under C.G.S. § 46b-497
☐ Determine child support amount under the Connecticut Child Support and Arrearage Guidelines (Regs., Conn. State Agencies § 46b-215a-1 et seq.)
☐ Prepare Financial Affidavit (JD-FM-6) for both parties
☐ Confirm filing fee or fee waiver application (JD-FM-75)
☐ Identify need for appointed counsel for an indigent alleged parent (Lavertue v. Niman, 196 Conn. 403 (1985); application for counsel accompanies the petition under C.G.S. § 46b-560(d))

Part 2. Verified Petition to Establish Paternity / Parentage

STATE OF CONNECTICUT
SUPERIOR COURT — JUDICIAL DISTRICT OF [____________________]
(☐ Family Support Magistrate Division)
Docket No. FA-[__________________]

VERIFIED PETITION FOR ESTABLISHMENT OF PARENTAGE

(Connecticut Parentage Act, C.G.S. §§ 46b-450 to 46b-553; procedure under § 46b-560)

Petitioner, by and through undersigned counsel (or pro se), respectfully states:

1. Parties and Standing

1.1 Petitioner [PETITIONER FULL LEGAL NAME] resides at [________________________________], [____________________], Connecticut, in the Judicial District of [____________________].

1.2 Respondent [RESPONDENT FULL LEGAL NAME] resides at [________________________________].

1.3 Petitioner has standing under C.G.S. § 46b-458 as the (☐ person who gave birth) (☐ child, through a representative) (☐ alleged genetic parent) (☐ alleged genetic parent proceeding under C.G.S. § 46b-571) (☐ State/Commissioner of Social Services under C.G.S. § 46b-562) (☐ intended parent under the Connecticut Parentage Act) (☐ presumed or de facto parent).

2. Jurisdiction and Venue

2.1 The Court has subject matter jurisdiction under the Connecticut Parentage Act, C.G.S. §§ 46b-450 to 46b-553, and § 46b-454.

2.2 Venue is proper in this judicial district under C.G.S. § 46b-461 because [☐ the person who gave birth resides in this judicial district] [☐ the alleged parent resides in this judicial district] [☐ other basis under § 46b-461: ____________________].

2.3 The Court has personal jurisdiction over Respondent under C.G.S. § 46b-460 and § 46b-560(c) based on [☐ personal service in Connecticut] [☐ residence in Connecticut at relevant times with payment of prenatal/child support, cohabitation with the child, or holding out as the parent].

3. Subject Child

3.1 The subject child is [CHILD FULL LEGAL NAME], born [__/__/____] in [____________________], (☐ Connecticut) (☐ State of [____]). Sex: [____]. State file number: [____________________].

3.2 The child resides with [____________________] at [________________________________].

4. Marital Status / Presumption (C.G.S. § 46b-488)

4.1 At the time of the child's birth, the person who gave birth was (☐ unmarried) (☐ married to Respondent) (☐ married to [____________________], a presumed parent under § 46b-488 whose parentage must be adjudicated under § 46b-489 or who must be joined).

4.2 A presumption of parentage under C.G.S. § 46b-488 (☐ does not apply) (☐ applies because: ☐ marriage at birth; ☐ birth within 300 days of a terminated marriage; ☐ holding out the child as the person's own for at least two years).

5. Acknowledgment of Parentage Status (C.G.S. §§ 46b-476 to 46b-487)

5.1 An Acknowledgment of Parentage (☐ has) (☐ has not) been executed and filed with the DPH parentage registry.

5.2 If filed: signature/effective date [__/__/____]; rescission window under § 46b-482 (☐ open) (☐ expired); any challenge would proceed under § 46b-483.

6. Allegations Supporting Parentage

6.1 Petitioner alleges that Respondent is a parent of the subject child based on:
☐ Genetic parentage — sexual intercourse during the probable period of conception, on or about [__/__/____] through [__/__/____];
☐ Holding-out conduct supporting a presumption under § 46b-488(a)(3);
☐ Prior admissions of parentage;
☐ Assisted reproduction / intended-parent status under the Connecticut Parentage Act (§§ 46b-509 to 46b-517);
☐ De facto parentage under § 46b-490;
☐ Other: [____________________].

7. Public Assistance / IV-D

7.1 The child (☐ is) (☐ is not) receiving public assistance (TANF, HUSKY/Medicaid) or child support enforcement services. If so, the Attorney General is or will be a party as provided in C.G.S. §§ 46b-231, 46b-562, and 46b-571.

8. ICWA

8.1 The child (☐ is not) (☐ is) (☐ may be) an Indian child under 25 U.S.C. § 1903. Tribe(s): [________________________________].

9. Relief Requested

WHEREFORE, Petitioner requests that the Court:

A. Adjudicate Respondent [RESPONDENT FULL LEGAL NAME] to be the legal parent of [CHILD FULL LEGAL NAME] (order adjudicating parentage under C.G.S. § 46b-466);

B. Order genetic testing under C.G.S. § 46b-497 if parentage is contested;

C. Direct the Department of Public Health to enter/amend the child's Birth Certificate under C.G.S. § 7-50 and § 19a-42a;

D. Order current child support under the Connecticut Child Support and Arrearage Guidelines (Regs., Conn. State Agencies § 46b-215a-1 et seq.);

E. Order past-due child support for the three years preceding filing under C.G.S. § 46b-569(a)(3);

F. Allocate health care coverage and unreimbursed medical expenses (C.G.S. § 46b-569(a)(2));

G. Address custody and parenting time consistent with the child's best interest;

H. Order a change of the child's name, if requested and for good cause (C.G.S. § 46b-467);

I. Award costs and attorney fees;

J. Grant such other relief as is just and equitable.

ANSWER FORM / APPLICATION FOR APPOINTMENT OF COUNSEL

In accordance with C.G.S. § 46b-560(d), the Petition, when served under § 46b-560(c), includes an answer form, a notice to the alleged parent, and an application for appointment of counsel written in clear and simple language for pro se defendants (see Lavertue v. Niman, 196 Conn. 403 (1985)).

VERIFICATION

I, [PETITIONER FULL LEGAL NAME], being duly sworn, depose and state that I have read the foregoing Petition and that the statements therein are true and correct to the best of my knowledge.

_________________________________
[PETITIONER FULL LEGAL NAME]

Subscribed and sworn to before me this [____] day of [____________________], [______].

_________________________________
Notary Public / Commissioner of the Superior Court
My Commission Expires: [__/__/____]

Submitted by:
_________________________________
[ATTORNEY NAME], Juris No. [____________________]
[FIRM NAME]
[ADDRESS] | [PHONE] | [EMAIL]
Counsel for Petitioner

Part 3. Acknowledgment of Parentage — Non-Signable Reference Checklist

NOT FORM VS-56: Do not sign or file this packet as an Acknowledgment of Parentage. Obtain the current VS-56 from a Connecticut birthing hospital, DSS Office of Child Support Services, or DPH. The DPH parentage page states that the form is not available online.

(C.G.S. §§ 46b-476 to 46b-487)

☐ The proposed acknowledging parent is eligible as an alleged genetic, presumed, or intended parent.

☐ No other acknowledged, adjudicated, assisted-reproduction, or surrogacy parent exists outside the proposed signers.

☐ The birth certificate does not identify another person as parent.

☐ No parentage action is pending, or every party to that action agrees to this AOP route.

☐ Both signers received the required oral and written notice before signing.

☐ If genetic parentage is uncertain, the participants stopped before signing and requested testing.

☐ Both signers completed VS-56 before the authorized witness or notarial officer.

☐ VS-56 was filed with the DPH Parentage Registry on [__/__/____].

☐ The statutory effective date is the later of the child's birth or DPH filing: [__/__/____].

☐ Each signer received a copy and current VS-57 rescission information.

VS-56 source, revision, execution dates, and filing proof: [________________________________]

Part 4. Summons, Notice, and Service

STATE OF CONNECTICUT
SUPERIOR COURT — JUDICIAL DISTRICT OF [____________________]
Docket No. FA-[__________________]

SUMMONS / ORDER TO APPEAR

TO: [RESPONDENT FULL LEGAL NAME]

Under C.G.S. § 46b-560, you are hereby summoned and ordered to appear in the Superior Court for the Judicial District of [____________________], located at [________________________________], on [__/__/____] at [____:____] [☐ a.m.] [☐ p.m.] — a date not more than ninety (90) days after issuance of this summons — to show cause why the relief requested in the attached Verified Petition for Establishment of Parentage should not be granted.

You have the right to file an Answer using the attached Answer Form within the time required by the Connecticut Practice Book.

NOTICE OF RIGHT TO COUNSEL: If you are an indigent alleged parent, you have the right to apply for appointed counsel. An Application for Appointment of Counsel is enclosed (C.G.S. § 46b-560(d)).

NOTICE OF RIGHT TO GENETIC TESTING: You have the right to request genetic testing under C.G.S. § 46b-497.

If you fail to appear after proper service, a default judgment of parentage may be entered against you, together with an order of child support and related relief (C.G.S. § 46b-560(a)(2)).

Date: [__/__/____]

_________________________________
Judge / Family Support Magistrate / Clerk / Commissioner of the Superior Court

RETURN OF SERVICE

I, [____________________], a State Marshal / proper officer / investigator employed by the Department of Social Services (C.G.S. § 46b-560(a)(1)(B)), certify that I served Respondent [RESPONDENT FULL LEGAL NAME] with a true copy of the Verified Petition, Summons, Answer Form, Notice of Rights, and Application for Counsel on [__/__/____] by:

☐ Personal service per Practice Book § 8-1 / C.G.S. § 52-57
☐ Abode service per C.G.S. § 52-57(a) at [________________________________]
☐ Service on the Secretary of the State per C.G.S. § 52-59b (nonresident)
☐ Service by publication per Practice Book § 11-20 (order entered [__/__/____])

Due return of process shall be made to the court not less than twenty-one (21) days before the hearing date (C.G.S. § 46b-560(a)(1)(B)). If the alleged parent is a nonresident or absent from the state, actual notice is required (C.G.S. § 46b-560(b)).

In IV-D cases, the Attorney General is a party as provided in C.G.S. § 46b-231: ☐ Served ☐ N/A

_________________________________
State Marshal / Proper Officer | Date: [__/__/____]

Part 5. Motion for Genetic Testing and Proposed Order

STATE OF CONNECTICUT
SUPERIOR COURT — JUDICIAL DISTRICT OF [____________________]
Docket No. FA-[__________________]

MOTION FOR GENETIC TESTING

Movant, pursuant to C.G.S. § 46b-497 (and, in IV-D support cases, § 46b-566), moves the Court (or Family Support Magistrate) for an Order directing the person who gave birth, the alleged genetic parent, and the subject child to submit to genetic testing. In support:

1. The Petition alleges Respondent is a genetic parent of [CHILD FULL LEGAL NAME], born [__/__/____].

2. Parentage is in dispute (or testing is necessary to support or rebut the allegations), and Movant is not barred from establishing parentage under § 46b-497(g).

3. Under C.G.S. § 46b-500, a person is identified as a genetic parent if genetic testing discloses at least a 99% probability of parentage (prior probability 0.50) and a combined relationship index of at least 100 to 1; such results support a temporary support order under § 46b-560(a)(2).

4. Costs of genetic testing shall be allocated under C.G.S. §§ 46b-501, 46b-565, and 46b-566 (paid by the state in IV-D cases where the requesting party is indigent, subject to recoupment).

WHEREFORE, Movant requests entry of the attached [Proposed] Order.

Date: [__/__/____]

_________________________________
[MOVANT/COUNSEL NAME], Juris No. [____________________]

[PROPOSED] ORDER FOR GENETIC TESTING

Based on the Motion, and applying C.G.S. §§ 46b-497 and 46b-498, the Court / Family Support Magistrate FINDS good cause and ORDERS:

1. The person who gave birth [PETITIONER FULL LEGAL NAME], Respondent [RESPONDENT FULL LEGAL NAME], and child [CHILD FULL LEGAL NAME] shall submit to genetic testing within thirty (30) days.

2. Testing shall be conducted by [____________________], a laboratory accredited by the AABB (or an accrediting body designated by the Secretary of the U.S. Department of Health and Human Services) as required by C.G.S. § 46b-498.

3. Sample collection appointments shall be scheduled at: [____________________].

4. Costs of testing shall (☐ be advanced by Movant) (☐ be paid by the State because the requesting party is indigent, in a IV-D case) (☐ be allocated as follows: ____________________), subject to C.G.S. §§ 46b-501, 46b-565, and 46b-566.

5. The laboratory shall file the report (self-authenticating under C.G.S. § 46b-499) with the Court and serve copies on all parties.

6. Failure of a party to submit to court-ordered testing without good cause may result in entry of a default judgment and adjudication of parentage (C.G.S. §§ 46b-497(h), 46b-560(a)(2)).

DATED this [____] day of [____________________], [______].

_________________________________
Judge / Family Support Magistrate

Part 6. Default Judgment of Parentage

STATE OF CONNECTICUT
SUPERIOR COURT — JUDICIAL DISTRICT OF [____________________]
Docket No. FA-[__________________]

DEFAULT JUDGMENT OF PARENTAGE

This matter came before the Court / Family Support Magistrate on Petitioner's motion for default judgment. Respondent [RESPONDENT FULL LEGAL NAME], having been duly served on [__/__/____], failed to appear.

Under C.G.S. § 46b-560(a)(2), where the alleged parent fails to appear, the court or family support magistrate shall hear the petitioner and, upon a finding that process was served, shall enter a default judgment of parentage and such other orders as the facts may warrant, and may continue the hearing. Upon motion, the court shall issue a temporary support order pending final judgment if it finds clear and convincing evidence of parentage, which — in cases involving an alleged genetic parent — shall include genetic test results meeting the requirements of C.G.S. § 46b-500.

The Court, having reviewed the record, including proof of service, the testimony of Petitioner, and (if applicable) genetic test results meeting § 46b-500 (at least 99% probability and a combined relationship index of at least 100 to 1), FINDS:

1. Service was properly perfected on [__/__/____].
2. Respondent has failed to appear.
3. Clear and convincing evidence supports entry of a parentage judgment.

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED:

A. Respondent [RESPONDENT FULL LEGAL NAME] is adjudicated the legal parent of [CHILD FULL LEGAL NAME], born [__/__/____].

B. Respondent shall pay current child support of $[____________________] per [☐ week] [☐ month] effective [__/__/____], computed under the Child Support and Arrearage Guidelines (Regs., Conn. State Agencies § 46b-215a-1 et seq.).

C. Past-due support from [__/__/____] (no more than three years prior to filing per C.G.S. § 46b-569(a)(3)) is awarded in the amount of $[____________________], payable at $[____________________] per [☐ week] [☐ month].

D. Respondent shall (☐ provide) (☐ contribute to) health care coverage; unreimbursed medical allocated [____]% Respondent / [____]% Petitioner (C.G.S. § 46b-569(a)(2)).

E. The Department of Public Health is directed to enter/amend the child's Birth Certificate under C.G.S. § 7-50 and § 19a-42a to name Respondent as a parent.

F. Costs of $[____________________] are taxed against Respondent.

DATED this [____] day of [____________________], [______].

_________________________________
Judge / Family Support Magistrate

Part 7. Final Order / Judgment of Parentage (with Child Support Reservation)

STATE OF CONNECTICUT
SUPERIOR COURT — JUDICIAL DISTRICT OF [____________________]
Docket No. FA-[__________________]

FINAL JUDGMENT OF PARENTAGE

The Court / Family Support Magistrate, having held a hearing on [__/__/____], heard testimony, reviewed the evidence (including any genetic test results), and being fully advised, FINDS:

1. Jurisdiction and venue are proper under the Connecticut Parentage Act (C.G.S. §§ 46b-454, 46b-460, 46b-461).

2. [CHILD FULL LEGAL NAME], born [__/__/____], is the child of Petitioner [PETITIONER FULL LEGAL NAME] and Respondent [RESPONDENT FULL LEGAL NAME].

3. Parentage is established by (☐ stipulation) (☐ genetic test result meeting § 46b-500 dated [__/__/____]) (☐ unrescinded Acknowledgment of Parentage under § 46b-479) (☐ unrebutted presumption under § 46b-488).

4. ICWA inquiry was conducted; the child (☐ is not) (☐ is) an Indian child.

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED:

A. Parentage. Respondent is the legal parent of the child for all purposes under Connecticut law (C.G.S. § 46b-466; § 46b-473).

B. Birth Certificate. The Department of Public Health is directed under C.G.S. § 7-50 and § 19a-42a to enter/amend the Birth Certificate to add Respondent as a parent. The child's name (☐ shall remain) (☐ shall change to ____________________) (C.G.S. § 46b-467).

C. Child Support.

1. Current: $[____________________] per [☐ week] [☐ month] from [__/__/____];
2. Past-due (up to 3 years pre-filing under § 46b-569(a)(3)): $[____________________] from [__/__/____];
3. Income withholding under C.G.S. § 52-362;
4. Health care coverage and unreimbursed medical (C.G.S. § 46b-569(a)(2)): [________________________________];
5. ☐ Child support is RESERVED for [____________________] pending [____________________].

D. Custody and Parenting Time. Custody is awarded to [____________________]. Parenting time per attached schedule.

E. Support and Birth-Related Expenses. Respondent shall pay support and maintenance as ordered under C.G.S. § 46b-569; past-due support is limited to the three years next preceding the filing (§ 46b-569(a)(3)).

F. Tax Dependency. Allocated as follows: [____________________].

G. Costs and Fees. [____________________] is awarded $[____________________] in attorney fees and $[____________________] in costs.

H. Reservation. The Court retains jurisdiction.

DATED this [____] day of [____________________], [______].

_________________________________
Judge / Family Support Magistrate

Part 8. Notice to Amend Birth Certificate

TO: Connecticut Department of Public Health — State Vital Records Office
410 Capitol Avenue, MS#11VRO, Hartford, CT 06134

NOTICE AND REQUEST TO AMEND BIRTH CERTIFICATE

Pursuant to C.G.S. § 7-50 and § 19a-42a and the Final Judgment of Parentage entered in the Superior Court for the Judicial District of [____________________], Docket No. FA-[__________________], dated [__/__/____] (certified copy attached), the undersigned requests entry/amendment of the following birth record:

Child's name on current certificate: [________________________________]
DOB: [__/__/____] | Place of birth (city/town): [____________________]
State file number: [____________________]

Amendments Requested
☐ Add parent: [PARENT FULL LEGAL NAME]

• DOB: [__/__/____]
• Birthplace: [____________________]
  ☐ Change child's surname to: [____________________]
  ☐ Other: [________________________________]

Enclosures
☐ Certified copy of Final Judgment
☐ DPH Vital Records amendment fee
☐ Self-addressed stamped return envelope

Date: [__/__/____]
_________________________________
Requesting Party
Printed Name: [________________________________]
Address: [________________________________] | Phone: [____________________]

Part 9. VS-57 Rescission and Court-Challenge Reference

NOT FORM VS-57 OR A FILE-READY PLEADING: Use the current DPH Rescission of Acknowledgment of Parentage form for a timely rescission. Obtain Connecticut counsel and the correct court or family-support-magistrate process for a later challenge.

A. VS-57 Rescission Before the Earlier Cutoff

1. VS-56 effective date, the later of birth or DPH filing: [__/__/____].
2. Sixtieth day after effective date: [__/__/____].
3. First court hearing involving the signer and an issue relating to the child: [__/__/____].
4. Counsel-confirmed earlier cutoff under C.G.S. § 46b-482: [__/__/____].
5. VS-57 was signed before a notary or authorized witness and filed with the DPH Parentage Registry on [__/__/____].
6. DPH filing receipt: [________________________________].

B. Challenge After the Rescission Period

1. The challenge relies on: ☐ Fraud ☐ Duress ☐ Material mistake of fact.
2. Supporting facts: [________________________________].
3. If the AOP involved alleged genetic parentage, testing evidence: [________________________________].
4. Every AOP signatory will be made a party as required by C.G.S. § 46b-483.
5. The challenger understands that responsibilities, including support, continue absent good cause.
6. The challenger bears the burden of proof and understands that, even if a permitted ground is proved, the AOP may be set aside only if the court or family support magistrate also finds that result is in the child's best interest under C.G.S. § 46b-475.
7. Requested testing, parentage, and birth-record relief for counsel to evaluate: [________________________________].

Reviewed on: [__/__/____] ___________________________________
[Participant or reviewing attorney]

Part 10. ICWA Inquiry and Notice

INDIAN CHILD WELFARE ACT INQUIRY (25 U.S.C. § 1901 et seq.)

1. Is the child a member or eligible for membership in a federally recognized tribe?
   ☐ Yes ☐ No ☐ Unknown

2. Is a biological parent a member of a federally recognized tribe (e.g., Mashantucket Pequot, Mohegan)?
   ☐ Yes ☐ No ☐ Unknown

3. Tribe(s) and enrollment number(s): [________________________________]

4. Names/tribal affiliations of biological grandparents/great-grandparents (if known): [________________________________]

Notice (25 U.S.C. § 1912): If ICWA applies, notice must be given by registered or certified mail, return receipt requested, to the parent or Indian custodian and to the child's tribe, with copies to the BIA Eastern Regional Office.

Tribal Right to Intervene (25 U.S.C. § 1911(c)): The tribe may intervene at any point.

_________________________________
[ATTORNEY/PETITIONER NAME] | Date: [__/__/____]

Sources and References

• Connecticut General Statutes Chapter 818 (Connecticut Parentage Act and Parentage-Related Provisions): https://www.cga.ct.gov/current/pub/chap_818.htm
• C.G.S. § 46b-560 (Formerly Sec. 46b-160) (Petition to adjudicate parentage; default judgment): https://www.cga.ct.gov/current/pub/chap_818.htm#sec_46b-560
• C.G.S. § 46b-482 (Rescission of acknowledgment) and § 46b-483 (Challenge): https://www.cga.ct.gov/current/pub/chap_818.htm
• C.G.S. §§ 46b-495 to 46b-505 (Genetic testing; § 46b-500 identification threshold)
• C.G.S. § 46b-488 (Presumption of parentage); § 46b-490 (De facto parentage)
• C.G.S. § 46b-569 (Formerly Sec. 46b-171) (Judgment; support; past-due support)
• Connecticut Parentage Act, P.A. 21-15 (effective January 1, 2022)
• Connecticut Department of Public Health, Office of Vital Records — Parentage: https://portal.ct.gov/DPH/Vital-Records/Parentage
• Connecticut DSS — Office of Child Support Services: https://portal.ct.gov/DSS/Child-Support/Child-Support
• Connecticut Judicial Branch Family Matters Forms: https://jud.ct.gov/webforms/
• Connecticut Judicial Branch — Law About Parentage: https://www.jud.ct.gov/lawlib/law/parentage.htm
• 25 U.S.C. §§ 1901–1963 (ICWA); 42 U.S.C. § 666(a)(5)
• Lavertue v. Niman, 196 Conn. 403 (1985) (right to counsel in a paternity/parentage action)