181 Conn. App. 404
Conn. App. Ct.2018Background
- Parties: Jay B. Packard (plaintiff) and Rebecca M. Packard (defendant), married; action for dissolution of marriage tried in Superior Court (Albis, J.).
- Judgment of dissolution entered April 7, 2017; defendant filed multiple amended appeals challenging postjudgment orders entered thereafter.
- Defendant’s appellate challenges included: (1) alleged errors in the April 7, 2017 judgment findings and orders; (2) July 28, 2017 order about renovations to the marital home; (3) August 18, 2017 order requiring defendant to sign medical‑information release to the guardian ad litem; and (4) October 6, 2017 orders facilitating sale of the marital home.
- Defendant was self‑represented on appeal and filed a lengthy brief that largely presented narrative facts but provided almost no legal analysis or authority connecting law to facts.
- Trial court judgment and postjudgment orders were affirmed because the appellate brief was inadequate; the court declined to consider the substantive claims due to failure to brief them properly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of April 7, 2017 dissolution findings and orders | Defend judgment and trial court rulings | Trial court’s findings, conclusions and orders are erroneous | Affirmed; appeal not considered due to inadequate briefing |
| July 28, 2017 order re: renovations to marital home | Order should stand | Order limiting renovations was erroneous | Affirmed; not reviewed on merits because defendant failed to brief legal bases |
| August 18, 2017 order requiring release of medical information to guardian ad litem | Order appropriate to permit GAL access | Order requiring release infringes privacy/was improper | Affirmed; court declined to address because of inadequate brief |
| October 6, 2017 orders facilitating sale of marital home | Orders facilitate equitable sale process | Orders interfere with defendant’s rights / were improper | Affirmed; claims not considered due to deficient briefing |
Key Cases Cited
- State v. Buhl, 321 Conn. 688, 138 A.3d 868 (Conn. 2016) (parties must set forth clear, full arguments and analyze law to facts for appellate consideration)
- Getty Properties Corp. v. ATKR, LLC, 315 Conn. 387, 107 A.3d 931 (Conn. 2015) (issues inadequately briefed when appellants provide no analysis applying law to facts)
- Taylor v. Mucci, 288 Conn. 379, 952 A.2d 776 (Conn. 2008) (claims receiving only cursory attention without substantive discussion are deemed abandoned)
- Kelly v. Kelly, 54 Conn. App. 50, 732 A.2d 808 (Conn. App. 1999) (context cited by defendant regarding contempt and protective aspects of certain orders)
- Tonghini v. Tonghini, 152 Conn. App. 231, 98 A.3d 93 (Conn. App. 2014) (self‑represented litigants given some latitude but must comply with procedural and substantive rules)