Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to open the judgment in this marital dissolution case on the basis of fraud, holding that the appellate court properly affirmed the trial court's denial of Defendant's motion to open.Following a trial, the dissolution court issued a decision dissolving the parties' marriage and issuing certain financial orders. Defendant later filed this motion claiming that Plaintiff had committed fraud by denying the existence of a sexual relationship with another man during the course of the marriage and by testifying that Defendant had physically assaulted her. The trial court denied the motion, and the appellate court affirmed. The Supreme Court affirmed, holding that there was no abuse of discretion in the denial of Defendant's motion to open. View "Conroy v. Idlibi" on Justia Law

The Supreme Court affirmed the judgment of the trial court terminating Mother's parental rights, holding that Mother was not entitled to relief on any of her claims of error.The Commissioner of Children and Families filed these petitions to terminate Mother's parental rights with respect to her daughter and son after Mother admitted that she had sent explicitly sexual photographs of her daughter to several persons, including a registered sex offender. During the proceedings, Mother filed four motions for a continuance. The trial court granted the first three motions but denied the fourth. The court then rendered judgments terminating Mother's parental rights. The Supreme Court affirmed, holding that the trial court did not abuse its discretion or violate Mother's constitutional due process right to present a defense to the termination of her parental rights in denying the motion for a continuance. View "In re Ivory W." on Justia Law

The Supreme Court affirmed the judgment of the trial court in this divorce proceeding, holding that there was no error.Plaintiff brought this divorce action, and the the trial court declared a mistrial. After a second trial Plaintiff appealed, arguing that the trial court prejudiced Plaintiff's credibility and displayed judicial bias and improperly awarded Defendant $65,000 in legal fees and $5000 in sanctions. The Supreme Court affirmed, holding (1) the doctrine of plain error did not require reversal in this case; and (2) the trial court properly awarded Defendant attorney's fees and sanctions. View "Ponns Cohen v. Cohen" on Justia Law

The Supreme Court dismissed this appeal from the trial court's judgment dismissing Mother's post-termination motion to intervene in her biological daughter Riley's juvenile case to obtain an order for visitation, holding that Mother failed to establish the party status necessary to support this Court's jurisdiction to consider her appeal.After the juvenile court terminated Mother's parental rights she filed a motion for post-termination visitation with Riley, citing this Court's decision in In re Ava W., 248 A.3d 675 (Conn. 2020), as support for the trial court's authority to issue a post termination of parental rights visitation order. The trial court denied the motion. The Supreme Court dismissed Mother's appeal, holding that, post termination, biological parents lack a legally cognizable interest to support a right to intervene in the juvenile case for the purpose of seeking visitation. View "In re Riley B." on Justia Law

The Supreme Court held that a spouse seeking pendente lite alimony, attorney’s fees, and expert fees during the pendency of a dissolution action must demonstrate that a postnuptial agreement that purportedly precludes such payments is invalid or otherwise unenforceable before the trial court may properly order the other spouse to make such payments. After their marriage, Plaintiff and Defendant executed a postnuptial agreement setting forth terms for the distribution of property and determining support awards in the event their marriage dissolved. Plaintiff later brought this action seeking dissolution of the marriage and temporary and permanent alimony. The trial court ordered Defendant to pay Plaintiff temporary alimony, current attorney's fees and a retainer for legal counsel, and a contribution toward specified future expert fees. The Supreme Court affirmed, holding that the trial court correctly determined that it need not determine the enforceability of the parties' postnuptial agreement before awarding Plaintiff alimony and litigation expenses. View "O.A. v. J.A." on Justia Law

The Supreme Court affirmed the judgment of the trial court concluding that enforcement of the prenuptial agreement between the parties was not unconscionable, with one exception, holding that the trial court did not err in ruling that the occurrence of the unforeseen events did not render the enforcement of the entire agreement unconscionable at the time of the dissolution.In 2010, shortly before the parties' marriage they executed a prenuptial agreement. In 2016, Plaintiff brought this action seeking dissolution of the marriage and enforcement of the prenuptial agreement. Defendant filed a cross-claim, asserting that the agreement was unenforceable because it was unconscionable at the time of the dissolution under Conn. Gen. Stat. 46b-36g(a)(2). The trial court dissolved the marriage and enforced the terms of the prenuptial agreement with the exception of an attorney's fees provision. The Supreme Court affirmed, holding that the trial court properly allowed the parties the benefit of their agreed-upon, pre-marriage bargain. View "Grabe v. Hokin" on Justia Law

The Supreme Court affirmed the order of the appellate court concluding that the trial court had abused its discretion in awarding Plaintiff $18,000 per month in permanent, nonmodifiable alimony, holding that the award constituted an abuse of discretion.On appeal, Defendant argued that the trial court's orders impermissibly double counted his income by considering it for business valuation purposes and further by awarding alimony on the basis of his income from those businesses. The appellate court agreed and reversed the judgment as to the trial court's financial orders and remanded the case for a new hearing on all financial issues. The Supreme Court affirmed in part and reversed in part, holding (1) the alimony award was an abuse of discretion; and (2) this Court's rule against double counting does not apply when, as in the instant case, the asset at issue is the value of a business. View "Oudheusden v. Oudheusden" on Justia Law

The Supreme Court reversed in part the judgment of the trial court granting Plaintiff's motion to vacate an arbitration award and denying Defendant's corresponding application to confirm the award, holding that the arbitrator did not exceed her authority or manifestly disregard the law, but the inclusion of issues related to child support in the award was improper.Before the parties were married they executed a premarital agreement. Years later, Plaintiff brought this action to dissolve the marriage, and the parties executed a binding agreement to arbitrate the dissolution action. At issue was the validity of the arbitrator's award dividing the equity in the parties' marital home and assigning responsibility for certain expenses related to child support. The trial court granted Plaintiff's motion to vacate the portion of the arbitration award. The Supreme Court reversed in part, holding (1) the trial court erred in ruling that the arbitrator's award exceed the scope of the parties' submission; (2) any error in distributing the equity in the marital home would not permit a court to vacate the arbitration award; and (3) because Connecticut law prohibits the inclusion of issues related to child support in arbitration awards, this portion of the award is reversed. View "Blondeau v. Baltierra" on Justia Law

The Supreme Court held that a trial court has authority to issue a posttermination visitation order that is requested within the context of a termination proceeding.During the termination hearing in this case, counsel for Child asked the trial court to consider an order of posttermination or postadoption visitation between Child and Mother. The trial court terminated Mother's parental rights and then denied the request for posttermination visitation, concluding that it lacked authority to issue an order for post termination visitation. The Supreme Court reversed and remanded the case for further proceedings, holding that a trial court has authority to issue an order for posttermiation visitation so long as the court finds it necessary or appropriate to the child's welfare. View "In re Ava W." on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming the trial court's denial of Mother's motion for reinstatement of guardianship rights to a parent under Conn. Gen. Stat. 45a-611, holding that the trial court improperly denied Mother's motion for reinstatement of guardianship with respect to her minor son.Specifically, the Supreme Court held (1) under section 45a-611, once a parent demonstrates that the factors that resulted in the removal of the parent as guardian have been satisfactorily resolved, the parent is entitled to a presumption that reinstatement of his or her guardianship rights is in the best interests of the child; and (2) the party opposing reinstatement must rebut the presumption by clear and convincing evidence; and (3) because it was unclear whether the trial court applied this presumption and because the court did not determine whether Mother had rebutted the presumption by clear and convincing evidence, the trial court erred in denying Mother's motion for reinstatement of guardianship. View "In re Zakai F." on Justia Law