Dept. of Income Maintenance v. Watts

In Dept. of Income Maintenance v. Watts, 211 Conn. 323, 326-27, 558 A.2d 998 (1989), the state agency that was the predecessor to social services appealed from a Probate Court decision approving "the disclaimer, by a conservator of an incapable person receiving state assistance, of his ward's interest in a testamentary trust, in view of the prohibition . . . against dispositions of the property of state aid recipients." Id. at 324. Examining the state's financial interest, the Court stated that the legally protected interest affected by the Probate Court decision "may be a direct pecuniary one, or it may consist of an injurious effect upon some legally protected right or status of the appellant." Id. at 326. Citing General Statutes 17-83e, the statutory predecessor to 17b-93, the Court ultimately held that the state had standing to appeal because it had the right to reimbursement of assistance, and the Probate Court decision could possibly adversely affect that right. Id. at 326-27.