Light v. Grimes
2012 WL 1940578
Conn. App. Ct.2012Background
- In May 2008 the trial court dissolved Libby Light and David Grimes's marriage and ordered equal division of marital assets with asset-by-asset valuations.
- On May 23, 2008 Light filed a motion for clarification re how financial accounts were to be divided, considering market fluctuations.
- Grimes separately filed a motion to reargue, correct, and clarify, seeking clarification on asset division and other post-decree issues.
- A July 21, 2008 hearing addressed valuation as of May 9, 2008 and arguments on the clarifications and other postjudgment requests.
- The court's December 15, 2008 clarification limited to market fluctuation adjustments and other postjudgment changes; it did not alter the May 9, 2008 valuation date.
- In 2010 Light sought a formal articulation that May 9, 2008 was the date of judgment, which the court held affirmed May 9, 2008 as the date of judgment; Grimes appealed the date-of-judgment ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether valuation date for assets is May 9, 2008. | Light argues valuation should be as of May 9, 2008. | Grimes contends postjudgment motions suspend finality and shift date of judgment. | Date of judgment remains May 9, 2008; assets valued as of dissolution date. |
| Whether a motion for clarification affects final judgment. | Light asserts clarification does not alter judgment date. | Grimes argues reconsideration of related orders could affect finality. | Clarification motions do not alter judgment or its finality; May 9, 2008 stands. |
Key Cases Cited
- Sunbury v. Sunbury, 216 Conn. 673 (1990) (valuation date for marital assets is the decree date; postdecree changes are not marital assets)
- In re Haley B., 262 Conn. 406 (2003) (clarifications may aid understanding but not alter terms of judgment)
- Weinstein v. Weinstein, 275 Conn. 671 (2005) (motion for reconsideration differs from clarification; not controlling here)