Clelford v. Bristol, 90 A.3d 998

Marriage of Clelford and Bristol in October 2004; they have one child and dissolved on January 17, 2012, with the separation agreement incorporated into the judgment; the agreement provided for joint legal custody and primary residence with the plaintiff and a provision for a de novo parenting plan review when the child enters kindergarten.
Article III of the separation agreement required the defendant to pay $1,575 per month for child support until the child is 18 (or 19 if still in high school) and to share unreimbursed medical expenses; the defendant also was to pay for the child’s medical insurance premiums.
Article IV barred alimony payments between the parties.
On February 5, 2013, the defendant moved to modify child support and the parenting plan, arguing lack of guideline deviation findings and that deviation at dissolution was inappropriate.
On April 3, 2013, the trial court denied nearly all relief, granting only a de novo hearing on the parenting plan; on May 9, 2013, the court denied the motion for reconsideration.
The defendant appealed on May 29, 2013, but the court affirmed due to an inadequate brief and record, declining to review the merits of the modification claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the denial of modification was proper given inadequate briefing/record.	Clelford argues Bristol’s challenge relies on pre-judgment events without adequate briefing.	Bristol contends the court erred by not applying Child Support Guidelines and by failing to make required deviation findings.	The claim is not reviewable due to inadequate brief/record; judgment affirmed.

Corrarino v. Corrarino, 121 Conn. App. 22, 993 A.2d 486 (2010) (abandoned because appellate brief insufficient guidance on issue)
Deutsche Bank National Trust Co. v. Bertrand, 140 Conn. App. 646, 59 A.3d 864 (2013) (claims about motions to compel discovery abandoned when not briefed)
Nowacki v. Nowacki, 129 Conn. App. 157, 20 A.3d 702 (2011) (adequate briefing required to review trial court rulings on dissolution matters)
Keating v. Ferrandino, 125 Conn. App. 601, 10 A.3d 59 (2010) (emphasizes briefing and record requirements on appeal)
Tuckman v. Tuckman, 308 Conn. 194, 61 A.3d 449 (2013) (guidelines and presumption in child support; need specific findings to rebut presumption)
Misthopoulos v. Misthopoulos, 297 Conn. 358, 999 A.2d 721 (2010) (affirms need for statutory criteria in support determinations)
Shaulson v. Shaulson, 125 Conn. App. 734, 9 A.3d 782 (2010) (overruled Bee on worksheet requirement for guidelines)