Mecartney v. Mecartney, 206 Conn. App. 243

Divorce judgment (1999) incorporated a separation agreement requiring David Mecartney to name Caroline Mecartney beneficiary of $900,000 life insurance while paying unallocated alimony, with a $3,500 annual premium cap.
In 2008 the trial court (Judge Axelrod) increased the required coverage from $900,000 to $1.8 million; the 2008 order did not mention the $3,500 premium cap.
In 2019 Mecartney let his prior policy lapse, claiming renewal would cost ~$65,000 and he was only obligated to pay $3,500; he applied to Prudential and was denied; his prior policy lapsed on March 24, 2019.
Mecartney procured a Lloyd’s policy effective May 1, 2019 naming Caroline beneficiary, but it contained a piloting exclusion; the court then ordered him to apply to five insurers for coverage without a piloting exclusion or, if unsuccessful, to transfer a $1.8M mortgage as security and refrain from private piloting until secured.
The trial court found Mecartney not credible that the $3,500 cap survived the 2008 increase and interpreted the 2008 order as eliminating that cap.
Mecartney later obtained three accidental-death policies (covering piloting) in addition to the Lloyd’s policy such that the defendant’s insurance entitlement was satisfied; the appellate court held challenges to the piloting prohibition and mortgage alternative moot and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the $3,500 annual premium limitation survived the 2008 order that doubled required coverage	Mecartney: the separation agreement limited his premium obligation to $3,500, so he could stop renewing expensive coverage	Caroline: the 2008 order increasing coverage to $1.8M omitted the $3,500 cap, eliminating it; court may clarify its own prior order	Court: upheld trial court — $3,500 limitation was eliminated; trial court’s credibility finding and interpretation not manifestly unreasonable
Whether the court erred by issuing an order prohibiting private piloting (an injunction) without findings of irreparable harm or inadequate remedy at law	Mecartney: injunction-like ban required traditional injunction findings; court lacked basis	Caroline: orders were within court’s remedial powers to protect its judgment	Moot — Mecartney later secured insurance meeting the amended agreement; no live relief sought
Whether requiring transfer of a $1.8M mortgage as alternative security exceeded equitable authority	Mecartney: mortgage condition exceeded court’s equitable powers	Caroline: alternative security was a permissible remedial device to secure the judgment	Moot for same reason as above; appellate court did not reach merits

Bauer v. Bauer, 308 Conn. 124 (Conn. 2013) (construction of judgments; deference to trial court’s interpretation of its own order)
Dicker v. Dicker, 189 Conn. App. 247 (Conn. App. 2019) (trial court may clarify ambiguous prior judgment under continuing jurisdiction)
DeMattio v. Plunkett, 199 Conn. App. 693 (Conn. App. 2020) (trial judge is sole arbiter of witness credibility)
Wilcox v. Ferraina, 100 Conn. App. 541 (Conn. App. 2007) (mootness doctrine and appellate jurisdiction)