Parisi v. Parisi, 315 Conn. 370

The parties’ 2010 dissolution incorporated a separation agreement, including an alimony buyout of $300,000 to be paid in lieu of periodic alimony.
The agreement labeled the payment as nontaxable to the recipient and nondeductible to the payor, with ambiguity about form of payment.
Extrinsic documents referenced the plaintiff’s financial affidavit and a spreadsheet showing retirement assets as the buyout source, but the agreement itself stated extrinsic documents have no force.
The defendant moved for contempt, clarification, and an order of compliance, arguing the buyout was not satisfied by the plaintiff’s proposed retirement-asset transfer.
The trial court found the agreement clear and concise and declined contempt; Appellate Court affirmed, but this Court granted certification and reformed the issue.
On appeal, the Court held the alimony buyout provision is ambiguous and remanded for a fact-finding to resolve intent and an appropriate order of compliance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the contempt verdict proper given the buyout ambiguity?	Parisi argues no contempt due to clear terms and lack of wilful noncompliance.	Parisi contends the buyout provision is clear and the proposed payment violated it.	Contempt not proper because provision is ambiguous, not a clear order.
Is the buyout provision sufficiently clear to support contempt if violated?	Parisi claims ambiguity precludes contempt.	Parisi argues the provision is unambiguous as written.	Provision is ambiguous; remand required to determine intent and interpretation.
Should the court issue an order of compliance or clarification?	Court should issue compliance based on plaintiff’s proposed payment.	Clarification needed to determine proper payment method under ambiguity.	Trial court abused discretion by not clarifying; remand for resolution and possible order of compliance.

In re Leah S., 284 Conn. 685 (2007) (clear and unambiguous orders required for contempt; ambiguity defeats contempt)
Dowd v. Dowd, 96 Conn. App. 75 (2006) (first inquiry on contempt is whether the order is clear and unambiguous)
Isham v. Isham, 292 Conn. 170 (2009) (ambiguity requires extrinsic evidence; contract interpretive framework)
Cruz v. Visual Perceptions, LLC, 311 Conn. 93 (2014) (ambiguous contract language must be interpreted in context)
Blaydes v. Blaydes, 187 Conn. 464 (1982) (civil contempt requires a clear, definite order)
Eldridge v. Eldridge, 244 Conn. 523 (1998) (abuse of discretion standard in contempt and equitable relief)
Passamano v. Passamano, 228 Conn. 85 (1993) (dissolution context; broad equitable power to fashion relief)
Marshall v. Marshall, 151 Conn. App. 638 (2014) (remand when ambiguity affects interpretation of alimony provisions)
AvalonBay Communities, Inc. v. Plan & Zoning Comm., 260 Conn. 232 (2002) (inherent authority to effectuate judgments; interpretation not altering judgment)