McKeon v. Lennon, 2013 WL 6818022

Maria F. McKeon (plaintiff) and William P. Lennon (defendant) dissolved their marriage; a postjudgment stipulation addressed Craig’s expenses, including auto insurance.
The Sept. 2, 2009 stipulation required Lennon to pay one-half of Craig’s auto insurance and related deductible impacts, with specific deductible provisions and cost-sharing language.
Craig was born in 1991 and was a minor at dissolution; by 2009 he was a postmajority-age student, with the stipulation referencing postmajority support terms.
In Oct. 2011 Lennon stopped paying one-half of Craig’s auto insurance; plaintiff sought Court to compel payment under the stipulation.
The trial court denied plaintiff’s motion to compel, and later articulated that the stipulation was ambiguous regarding its duration.
On appeal, the court ultimately held the stipulation’s termination is self-executing by operation of law and affirmed the trial court’s denial, applying 46b-84(b) and related authority.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stipulation is ambiguous as to duration	McKeon argues the lack of an end date shows continuing obligation.	Lennon argues absence of duration language creates ambiguity requiring modification.	Stipulation is unambiguous; termination by operation of law upon Craig’s graduation.
Whether the termination of the obligation upon Craig’s graduation should be read as continuing or not	Termination should not be self-executing; but requires court action to modify.	Obligation ends by operation of law after Craig’s high school graduation.	Termination self-executing upon Craig’s graduation; no post-majority obligation.
Whether trial court properly denied relief when defendant stopped paying without a modification motion	A court order must be obeyed until modified; self-help is improper.	Self-executed termination allowed by statute; no modification needed.	The court did not abuse discretion; result dictated by law regardless of self-help.

Loughlin v. Loughlin, 93 Conn. App. 618 (2006) (postmajority support requires written agreement or statute)
Passamano v. Passamano, 228 Conn. 86 (1993) (child support beyond eighteen requires express written agreement)
Eldridge v. Eldridge, 244 Conn. 523 (1998) (self-executing orders exception not present here)
Sablosky v. Sablosky, 268 Conn. 713 (2001) (modify vs. self-help for ambiguous orders; obedience until modification)
Guaragno v. Guaragno, 141 Conn. App. 337 (2013) (contract interpretation and ordinary meaning governing)
Prymas v. New Britain, 122 Conn. App. 511 (2010) (ambiguous contract interpretation subject to plenary review)
Bock v. Bock, 127 Conn. App. 553 (2011) (postmajority educational support requires written agreement)
Hopson v. Hopson, 136 Conn. App. 690 (2012) (contract interpretation and standard of review in family matters)