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28 ¦ JULY 6, 2020 CONNECTICUT OPINIONS

SUPREME COURT The court therefore held that Florida has the
jurisdiction to make an original custody de-
CIVIL PROCEDURE termination. The court reversed the lower
court’s ruling.

Connecticut Does Not Have Jurisdiction DAMAGES
To Make Any Rulings In Lawsuit
Involving “Predictive Neglect” Of Child Police Officer Was Shielded By
Born In Florida Governmental Immunity After Pursuing
A Motorist That Resulted In A Fatal
CASE: In re Teagan K.-O. Accident
COURT: Connecticut Supreme Court
DOC. NO.: SC 20245 CASE: Borelli v. Renaldi
COURT: Connecticut Supreme Court
COURT OPINION BY: McDonald DOC. NO.: SC 20232
DATE: June 24, 2020 • PAGES: 29
The respondents had three children together. COURT OPINION BY: Kahn
Their first two children were adjudicated ne- DATE: June 24, 2020 • PAGES: 22
glected. Respondents then moved to Florida The decedent was in the backseat of a friend’s
with no intention of returning. Teagan was vehicle when the named defendant, a police
born in 2018 in Florida, where she was imme- officer, attempted to pull the car over. A high-
diately flagged for removal from the respon- speed chase resulted where the decedent was
dents’ care. The Commissioner of Children killed. Plaintiff sued defendant, the town,
and Families filed a petition to adjudicate Tea- and defendant’s shift supervisor for negli-
gan as neglected on the basis of “predictive gence. Defendants moved for summary judg-
neglect.” The trial court denied the respon- ment on the basis of governmental immunity,
dent father’s motion to dismiss the petition. and the trial court granted their motions. The
The court reversed the trial court’s judgment. court affirmed. The issue before the court was
The respondent father argued that a Con- whether a town and its municipal police of-
necticut trial court does not have subject mat- ficers are shielded by government and quali-
ter jurisdiction over Teagan’s neglect petition fied immunity from liability for the decision
because any neglect of her would not occur to initiate a high-speed chase that lasted less
in this state. The court agreed, finding there than two minutes and resulted in a fatal ac-
was no allegation that Teagan would likely be cident. The court indicated that the issue on
neglected within Connecticut. It found that appeal is very narrow: whether governmental
the only reason that Teagan was in this state immunity applies to an officer’s decision to
was because of another state’s action to re- engage in a pursuit, not whether immunity
move her from the parents’ state of residence. shields the officer from the manner of driving

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