162 Conn.App. 451
Conn. App. Ct.2016Background
- Parties married in New York (1989); three children; dissolution judgment entered 2010 following a contested trial.
- Postdissolution motion (June 12, 2013) sought to manage Williamsbridge Road property listing; trial court set listing at $499,000 with 90-day cycle and 5% reductions thereafter.
- Property sold to a third party in August 2015; appellate mootness issue raised for listing-price appeal.
- Appeals AC 36454/36874 challenge method of sale of the marital home; those appeals later found moot and dismissed.
- Appeals AC 37424/37425 challenge: (a) downward modification of alimony/child support, (b) motion to disqualify the judge for bias, (c) counsel fees; plaintiff argues rulings should be reviewed.
- Appellate court found the defendant’s briefing inadequate and dismissed/rejected the challenged claims due to briefing deficiencies and mootness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness of listing-price appeals | Pryor contends sale moots the listing-price issues. | Pryor argues Champagne distinctions save the appeal. | Appeals dismissed as moot. |
| Adequacy of briefing for postdissolution motions | N/A (plaintiff’s briefing cited as adequate in context) | Defendant’s briefs are inadequately briefed. | Claims in AC 37424/37425 dismissed for inadequate briefing. |
| Review of postdissolution rulings other than those briefed | N/A | N/A | Additional issues waived/dismissed due to inadequate briefing. |
Key Cases Cited
- Champagne v. Champagne, 85 Conn. App. 872 (Conn. App. 2004) (mootness where marital home sale occurred during pendency of appeal)
- Kennedy v. Putman, 97 Conn. App. 815 (Conn. App. 2006) (threshold mootness and adjudicative relief analysis)
- Zappola v. Zappola, 159 Conn. App. 84 (Conn. App. 2015) (adequacy of briefing; abandonment of issues for lack of record support)
- Lederle v. Spivey, 113 Conn. App. 177 (Conn. App. 2009) (rulings not evidence of bias; need for adequate record support)
- Morgan v. Morgan, 139 Conn. App. 808 (Conn. App. 2012) (sale of property during pendency renders claims about sale moot)
- Fiddelman v. Redmon, 59 Conn. App. 481 (Conn. App. 2000) (mootness when marital home sale closes; relief cannot be undone)
- Episcopal Church in the Diocese of Connecticut v. Gauss, 302 Conn. 386 (Conn. 2011) (waiver of issues not raised in appellate briefing)