A biological parent who seeks visitation with an adopted child must prove that the parent has a parent-child relationship with the minor child and that denial of visitation will cause real and significant harm to the minor child. The petitioner requested visitation with an adopted child and alleged that she is the minor child's biological mother and that the respondents are the adoptive parents. The respondents moved to dismiss and requested a protective order, to bar the petitioner from contacting them, the minor child and the child's teachers and coaches, and also to prevent the petitioner from appearing in public, if she knows that the respondents or the minor child are likely to be present. The petitioner did not allege that she possesses a parent-child relationship with the minor child and that denial of visitation will cause real and significant harm to the minor child. The court denied the petitioner's request for visitation. The court was not persuaded that the petitioner's request for permission to visit the minor child qualified as harassment or resulted in severe harm to the respondents. The court warned the petitioner that if she files another application that lacks a legal basis, she may be ordered to pay attorneys' fees, or become the subject of a restraining order, pursuant to Connecticut General Statutes §46b-15. '[T]he relief requested by the respondents,' wrote the court, 'is overly broad in that it even seeks to bar the applicant from appearing in a public place where the respondents or the child will be.' The court denied the respondents' request for a permanent injunction. The petitioner did not realize that she lacked a basis for visitation at the time that she filed the request, and the court denied the respondents' request for attorneys' fees.

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