July 15, 2026
Paying for Private Secondary School
A 2026 decision of the Connecticut Appellate Court in Zheng v. Xia, 237 Conn.App. 242 (2026), reiterates the holdings of two long standing Supreme Court decisions.
First, the 1981 case of Hardisty v. Hardisty, 183 Conn. 251 (1981) addressed responsibility for payment of private secondary school costs at the time of the divorce/judgment. Hardisty held that : a parent cannot be ordered to contribute to the cost of private secondary school if a) there is no family tradition of attending private school, b) there is no evidence that the local public school is inadequate or unsuitable, and c) the parent whom the court is being asked to order payment is opposed to the private schooling.
Second, the 1994 case of Borkowski v. Borkowski, 228 Conn. 729 (1994) addressed the standard for a court modifying an existing child support order, such as an order for payment of secondary school expenses. Borkowski held that to order a modification : a) there must be a substantial change in circumstances, citing the relevant statute CGS Section 46b-86(a), and b) the change must consist of a change since the last court order.
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