Briefly discuss the three leading approaches to determining the disposition of a pre-embryo upon divorce, as discussed by the Connecticut Supreme Court in Bilbao v. Goodwin: (1) the contractual approach, (2) the balancing approach, and (3) the contemporaneous mutual consent approach.

Which of the approaches does Connecticut use as a first step in determining the disposition of a pre-embryo? Do you agree with the Connecticut Supreme Court's reasoning to use this approach? Why do you think different states use different approaches?