Until recently, and almost consistently, the Child and Family Services Agency (CFSA) would in cases where a non-custodial non-petitioned biological parent intervenes in the neglect proceedings and seeks custody of the child – would require that parent to go through the rigorous and rather arduous task of the ICPC approval traditionally reserved for out of state placement with a foster family or an out of state pre-adoptive home. The Supreme Court of Connecticut in an opinion published on July 19, 2012 (IN RE EMONI W. ET AL), dissected the ICPC statutory language and clearly ruled that the biological non-custodial parents
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