## Facts

- Thomas C. was 16 years old (born May 29, 1979) when his parents, Jeffrey and Maureen C., filed a petition seeking his emancipation.
- Thomas had long-standing behavioral problems at school and at home and had been diagnosed with attention deficit disorder.
- In school, Thomas attended regular classes and received psychological support; he was described as intelligent but struggling academically.
- His performance briefly improved while taking Ritalin, but the improvement did not last, and it was suspected that he was not taking the medication.
- Thomas frequently violated school rules, was suspended many times, and dropped out of school shortly before turning 16.
- At home, Thomas was verbally abusive toward his parents and siblings and physically abusive toward his younger siblings.
- Thomas was arrested following a dispute with his father.
- Thomas refused to return to school, refused counseling, and refused to seek employment.
- Despite the conflict, Thomas remained totally dependent on his parents for housing and necessities such as food.
- The parents sought emancipation under Connecticut General Statutes § 46b-150 (as amended in 1995), largely due to their inability to control Thomas and fear of potential civil or criminal liability arising from his conduct.
- Thomas’s father told the court he did not plan to immediately put Thomas out of the home or stop supporting him; the parents wanted emancipation mainly as a pressure tactic to induce obedience.
- If Thomas were declared emancipated, there was no plan for how he would support himself or meet basic needs.

## Issues

1. Whether a court may declare a 16-year-old emancipated under Conn. Gen. Stat. § 46b-150 when the minor remains in the parents’ home and is financially dependent on them.
2. Whether emancipation may be granted when the parents’ aim is to reduce their responsibilities and exposure to liability for a noncompliant child rather than to recognize an already independent status.

## Decision

- The court denied the petition for emancipation.
- The court found the statutory grounds for emancipation were not satisfied because Thomas was not living apart from his parents and was not managing his own financial affairs.
- The court declined to use emancipation as a coercive remedy for family conflict or as a way to shift responsibility for a dependent minor who refused school and work.
- The court also considered the practical consequences of emancipation and the absence of any workable plan for Thomas’s self-support.

## Legal Principles

- Emancipation of a minor is governed by Conn. Gen. Stat. § 46b-150; a court may grant emancipation only on statutorily defined grounds.
- A claimed basis for emancipation premised on independence requires evidence that the minor is living apart from parents and actually managing personal financial affairs; total parental support and residence in the family home defeat that basis.
- Emancipation is intended to recognize a minor’s existing, functional independence, not to create independence for a minor who lacks means of self-support.
- A minor’s disobedience, parental loss of control, and parental fear of liability do not, standing alone, supply a statutory basis for emancipation.
- A court may consider the real-world effects of emancipation, including whether emancipation would leave a dependent minor without necessary support and structure, when assessing whether emancipation is warranted under the statute.

## Conclusion

In *In re Thomas C.*, the Connecticut Superior Court (Juvenile Matters) denied parents’ request to emancipate their 16-year-old son because he remained fully dependent on them and was not living independently or managing his own finances as required by the emancipation statute. The court rejected emancipation as a tool to handle a defiant teenager or to reduce parental responsibility and liability where the minor had no plan or capacity for self-support.


In re Thomas C., 691 A.2d 1140 (1996)