AC47229 - K. S. v. C. S. ("The plaintiff, K. S., appeals from the judgment of the trial court dissolving her marriage to the defendant, C. S., which included a finding of contempt against the plaintiff. On appeal, the plaintiff claims that the court improperly (1) entered an order in the judgment of dissolution prohibiting contact between the parties’ minor child and the plaintiff’s boyfriend, A, (2) awarded the defendant final decision-making authority with respect to the child’s medical and educational issues, (3) granted the defendant’s motion for contempt alleging violations of the court’s interim order prohibiting contact between the child and A, (4) ordered the plaintiff to pay attorney’s fees in connection with the defendant’s motions for contempt, (5) entered orders regarding child support, specifically challenging its factual findings as to the parties’ incomes, and (6) entered orders regarding the division of marital property, specifically challenging its factual finding regarding the equity in the marital home.

"We disagree with the plaintiff’s first and second claims. With respect to the third and fourth claims, we conclude that, although the court did not abuse its discretion in finding the plaintiff in contempt of its no contact interim order, its awards of attorney’s fees constituted an abuse of its discretion. Accordingly, we remand the case for reconsideration of the attorney’s fees awards. Finally, we agree with the plaintiff’s fifth and sixth claims and conclude that the court made clearly erroneous factual findings underlying its child support and division of marital property orders. Because these orders are not severable from the other financial orders, we reverse the judgment of the trial court with respect to the financial orders and remand this case for a new trial on all financial issues.")

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AC46948 - Prioleau v. Agosta ("In this child custody action, the self-represented plaintiff, Keith Prioleau, appeals from the judgment of the trial court denying his motion to correct a child support order entered by a family support magistrate in a separate child support action and his subsequent motion to reargue his motion to correct. On appeal, the plaintiff claims that the court erroneously concluded that it lacked the authority to modify the child support order. We affirm the judgment of the court.")

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AC 47492 - Laffin v. Laffin ("In this postjudgment dissolution matter, the self-represented defendant, Brian E. Laffin, appeals from the judgment of the trial court denying his motion for modification of his obligation to pay periodic alimony to the self-represented plaintiff, Heather M. Laffin, now known as Heather M. Bruneau. On appeal, the defendant claims that the court erred in (1) failing to find that his job loss constituted a substantial change in circumstances warranting a modification of his alimony obligation pursuant to General Statutes § 46b-86 (a), and (2) failing to address his claim that alleged false representations by the plaintiff regarding her financial condition warranted modification of his obligation. We affirm the judgment of the trial court.")

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The 2025 edition of the Glossary of Connecticut Family Law Terms research guide has been posted to our research guides webpage.

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The 2025 edition of our research guide on Bankruptcy and the Family has been posted to our research guides web page.

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AC46535 - Jacob-Dick v. Dick ("The defendant, Charles H. Dick, appeals from the judgment of the trial court granting the postjudgment motion for contempt filed by the self-represented plaintiff, Jennifer R. Jacob-Dick, known also as Jenna McPartland. On appeal, the defendant claims that the court (1) abused its discretion in finding him in contempt and (2) imposed an improper criminal sanction. We agree with the defendant’s first claim and, accordingly, reverse the judgment of the trial court.")

AC47091 - L. K. v. K. K. ("In this marital dissolution action, the plaintiff, L. K., appeals from the trial court’s denial of her postjudgment motion for an order requiring the defendant, K. K., to pay the balance of attorney’s fees awarded as a part of the judgment of dissolution. The plaintiff claims that the court improperly denied her motion for order on the ground that the plaintiff had failed to provide the court with a new, court-ordered fee affidavit. The plaintiff argues that the fee affidavit was unnecessary, waived by the defendant, and impossible to obtain or recreate. We disagree and affirm the judgment of the court.")

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AC45708 - Margarita O. v. Fernando I. ("The self-represented defendant, Fernando I., appeals from the postdissolution judgment of the trial court finding the plaintiff, Margarita O., in contempt of a court order, which concerned the listing of the parties’ marital residence for sale, and distributing the proceeds from the sale of the residence, as well as from the court’s denial of his postjudgment motion to disqualify the judicial authority. Additionally, the plaintiff cross appeals from the court’s contempt finding. On direct appeal, we distill the defendant’s claims to be that the court (1) incorrectly calculated his share of the sale proceeds in several ways, including by reducing his share by $25,000 in postsecondary educational support that the court improperly ordered him to pay to the plaintiff, and (2) improperly denied his motion to disqualify. On cross appeal, the plaintiff claims that the court improperly found her in contempt because the order underlying the contempt finding was not clear and unambiguous. Turning first to the plaintiff’s cross appeal, we conclude that the order at issue was clear and unambiguous, and, therefore, we reject the plaintiff’s claim challenging the court’s contempt finding. With respect to the defendant’s direct appeal, we agree only with the defendant’s claim that the court improperly ordered him to pay, and deducted from his share of the sale proceeds, $25,000 in postsecondary educational support. Accordingly, we reverse in part the judgment of the trial court.")

AC46578 - Lukasik v. Kopinska ("The plaintiff, Czeslaw Lukasik, appeals from the judgment rendered by the trial court in this child custody action filed against the defendant, Karolina Kopinska. On appeal, the plaintiff claims that (1) the court abused its discretion by failing to make a specific finding of the presumptive child support amount before applying the deviation criteria, and (2) its child support award of $600 per week was arbitrary and not in accordance with the child support guidelines (guidelines). We agree with the plaintiff’s second claim and conclude that the court improperly deviated from the guidelines. Accordingly, we reverse the judgment with respect to the order of child support and remand the case for further proceedings on that issue. We affirm the judgment in all other respects.")

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AC 46459 - Marzaro v. Marzaro ("The defendant Sebastiano G. Marzaro appeals from the judgment of the trial court dissolving his marriage to the plaintiff, Sheri Marzaro. On appeal, the defendant claims that (1) the court abused its discretion in fashioning its financial orders by making a grossly disproportionate property distribution in the plaintiff’s favor and by assigning all of the marital debt to him, (2) the court improperly concluded that the parties’ marital residence, which was held in the Marzaro Family Trust (trust), was subject to equitable distribution, (3) the plaintiff failed to plead sufficient facts to support a cause of action in counts two and three of her revised complaint and (4) the court improperly denied his motion for contempt and failed to order the plaintiff to disclose certain financial documents. We affirm the judgment of the trial court.")

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The 2025 edition of our research guide on Equitable Distribution of Marital Property in Connecticut has been posted to our research guides web page.

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AC 47068 - Karosi v. Karosi ("In this postjudgment dissolution matter, the defendant, Donna Karosi, appeals from the judgment rendered by the trial court granting in part the motion for order filed by the plaintiff, Robert Karosi. On appeal, the defendant claims that the court acted in excess of its statutory authority when it ordered a change in custodianship over the education savings account established pursuant to 26 U.S.C. § 529 (§ 529 account) for the benefit of the parties’ then minor child. We affirm the judgment of the trial court.")

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AC 46883 - Cardona v. Padilla ("The plaintiff, Priscilla I. Cardona, appeals from the judgment of the trial court awarding the defendant, Raymond J. Padilla, who lives in Florida, primary physical custody of their minor child (child) and ordering visitation for the plaintiff with the child. On appeal, the plaintiff claims that the court abused its discretion in making its custody and visitation orders and by issuing an order pursuant to Practice Book § 25-26 (g) when neither party has filed excessive motions or pleadings in this case. We agree with the plaintiff as to the court’s visitation order and, accordingly, reverse the judgment of the court in part and remand the case for a new hearing on visitation.")

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AC 46576 - Pasciolla v. Pasciolla ("In this postdissolution matter, Carollyn Mainolfi Pasciolla—the executrix of the estate of the defendant, James Pasciolla, and an intervenor in the underlying dissolution action (executrix)—appeals from the judgment of the trial court dismissing, for lack of standing, her second amended postjudgment motion to modify the lifetime alimony award awarded to the plaintiff, Christine Pasciolla. On appeal, the executrix contends that the court incorrectly concluded that she lacked standing to seek a postjudgment modification of alimony. We agree and, accordingly, reverse the judgment of the trial court.")

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SC 20830 - D. S. v. D. S. ("In this appeal, we consider whether an interest in an unfunded retirement benefit constitutes property pursuant to General Statutes § 46b-81, when that interest will never vest because it may be unilaterally revoked by a third party at any time. The plaintiff, D. S., appeals from the judgment of the Appellate Court affirming the trial court’s judgment of dissolution. On appeal, the plaintiff claims that the Appellate Court incorrectly concluded that the interest of the defendant, D. S., in a potential stream of retirement payments (retirement payments) pursuant to the partnership agreement of her law firm (firm) was too speculative in nature to constitute marital property subject to equitable distribution under § 46b-81. The plaintiff further claims that the Appellate Court incorrectly concluded that the trial court did not abuse its discretion in ordering an alimony award that was tied to her employment at the firm. We affirm the judgment of the Appellate Court.")

• SC 20830 Dissent - D. S. v. D. S.

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AC46649 - Lenczewski v. Lenczewski ("In this postjudgment dissolution matter, the defendant, Vincent Lenczewski, appeals from the judgment of the trial court resolving several motions filed by the defendant and the plaintiff, Jennifer Lenczewski. Specifically, the defendant claims on appeal that the court (1) abused its discretion in denying his motion for a reduction in his alimony obligation, (2) improperly denied his motion for contempt with respect to the plaintiff's claimed failure to comply with a provision of an arbitration award, (3) improperly found him in contempt, and (4) abused its discretion in awarding attorney's fees to the plaintiff. We affirm the judgment of the court.")

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The 2024 edition of our research guide on Modification of Judgments in Family Matters has been added to our research guides web page.

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SC 20982 - K. S. v. R. S. ("This case comes to us on appeal from the trial court’s judgment in a complex marital dissolution action. The case concerns, among other issues common to divorce proceedings such as custody and child support, the authority of a trial court in Connecticut to decline to give full faith and credit to the judgments and court orders of another state that impact the marital estate. We conclude that the trial court was required to give full faith and credit to the orders of the other state. Accordingly, we affirm in part and reverse in part the judgment of the trial court.")

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he 2024 edition of our research guide on Breach of Promise to Marry and Return of Engagement Ring and Courtship Gifts has been added to our research guides web page.

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AC 46365 - Thomas v. Cleary ("In this custody matter, the self-represented defendant, Meghan M. Cleary, appeals from the judgment of the trial court adjudicating several postjudgment motions. On appeal, the defendant claims that the court improperly (1) granted a postjudgment motion for modification of custody brought by the plaintiff, Kenneth L. Thomas, (2) ‘‘displayed consistent bias’’ against her, and (3) found that she had an imputed earning capacity of $90,000. We affirm the judgment of the trial court.")

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AC 46271 - Kosar v. Giangrande ("In this dissolution action, the defendant, Marie Giangrande, appeals following the trial court’s judgment dissolving her marriage to the plaintiff, Jaromir Kosar, and the trial court’s order on the plaintiff’s amended motion for contempt and injunctive relief. On appeal, the defendant claims that the court, Hon. Michael E. Shay, judge trial referee, (1) abused its discretion and deprived her of due process of law by limiting her case-in-chief on the plaintiff’s pendente lite amended motion for contempt and motion for injunctive relief to only fifteen minutes and (2) abused its discretion in refusing to hear her motion to open the parties’ pendente lite agreement regarding the marital home. She also claims that the court, Moukawsher, J. (3) committed plain error by presiding over the parties’ dissolution trial after conducting a hearing on the motion of the defendant’s then counsel to withdraw his appearance and (4) made credibility determinations on improper bases. We agree with the defendant on her first claim but disagree with her on her other claims. Accordingly, we reverse in part and affirm in part the judgment of the trial court.")

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AC 46656 - Yanavich v. Yanavich ("The defendant, Joseph Yanavich, has presented two issues for our review in this postmarital dissolution appeal. First, he claims that the trial court improperly denied his motion to modify alimony and child support. Second, he claims that the court improperly failed to impose sanctions on the plaintiff, his former wife, Jennifer M. Yanavich, after finding her in contempt for violating the terms of the dissolution judgment. More specifically, as to his first claim, he seeks our determination as to whether the retained earnings of a subchapter S corporation derived from past years’ earnings and distributed to its sole shareholder in a later year or years can be considered present income to the shareholder for purposes of setting his or her alimony and child support obligations. As to his second claim, he argues that the court abused its discretion by not imposing sanctions on the plaintiff after finding that she wilfully failed to prevent the minor children from being inappropriately exposed to the parties' disputes over financial issues in violation of the explicit terms of their marital separation agreement. We affirm the judgment of the trial court.")

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