F. S. v. J. S., 223 Conn.App. 763

The case arises from a marital dissolution, with an unresolved dispute over custody and parenting time for the parties' minor child, O.
The defendant, J. S., is self-represented and appeals from the trial court's award of sole legal and physical custody to the plaintiff, F. S., and restrictions on his visitation rights.
The matter saw extensive litigation, including numerous motions and continuances, resulting in procedural orders limiting further motion filings without leave of court due to their volume and repetitiveness.
The trial court considered evidence from social workers, therapists, and a psychologist’s custody evaluation; delays occurred due to COVID-19 and health-related requests for accommodation by the defendant.
The defendant was diagnosed with narcissistic personality disorder by two evaluators; the court’s custody determination was based on findings of the defendant’s poor parenting, lack of progress, and emotional harm to the child.
The trial court imposed conditions on the defendant’s future visitation and modification rights, tying them to evidence of treatment and consistent compliance with access schedules.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ADA Accommodation	Reasonable accommodations were granted; court adjusted schedule per medical advice	Court failed to maintain previously granted accommodation, violating ADA	No ADA violation; accommodations were reasonable and modifiable as circumstances changed
Use of Defendant’s Mental Health	Court rightly considered mental health as one of many factors impacting best interest of child	Court relied improperly on mental health diagnosis to restrict custody/visitation	Proper to consider mental health; not sole basis for custody order
Reliance on Custody Evaluation	The court evaluated updated evidence and did not rely solely on old report	Court improperly relied on stale custody evaluation	No abuse of discretion; court weighed current evidence, report's age affected weight, not admissibility
Judicial Discretion over Motions	Discretionary order was necessary to control excessive, duplicative motions	Limiting motions improperly denied access to court, delayed case	No error; order was within trial court’s discretion in response to abusive filings

Ahneman v. Ahneman, 243 Conn. 471 (trial court generally must decide motions properly before it, but exceptions allowed for abuse or extreme situations)
Strobel v. Strobel, 92 Conn. App. 662 (court may limit abusive/repetitive filings in contentious custody proceedings)
Barros v. Barros, 309 Conn. 499 (child custody decisions hinge on best interests of the child)
Coleman v. Bembridge, 207 Conn. App. 28 (appellate review of factual findings in family cases is for clear error)
Merkel v. Hill, 189 Conn. App. 779 (courts may consider professional custody evaluations as part of best interest determination)
Hall v. Hall, 186 Conn. 118 (modification of custody requires material change of circumstances, only applies after initial custody determination)