Hunte v. Blumenthal
In Hunte v. Blumenthal, 238 Conn. 146, 680 A.2d 1231 (1996), the issue was whether foster parents qualify as employees of the state, which would make them eligible for indemnification in a wrongful death action. 238 Conn. at 147-48.
In answering that question, our Supreme Court again distinguished the rights of natural parents and foster parents.
The court stated that "the rights of foster parents are defined and restricted by statute. Foster families do not have the same rights as biological families or adoptive families. Rather, the expectations and entitlements of foster families can be limited by the state. . . . Foster parents are entrusted with foster children on a temporary basis only. . . . Foster parents do not enjoy a liberty interest in the integrity of their family unit." Id., at 164.
The Connecticut Supreme Court found that foster parents were employees of the State, rather than independent contractors. Id. at 1241.
The facts of Blumenthal are distinguishable because, there, the commissioner of the DCYF is the guardian of the children placed in foster care and "has the authority to make day-to-day decisions concerning the activities of the foster child." Id. at 1235-36.