Ricketts v. Ricketts, 203 Conn.App. 1

Parties divorced in 2018; dissolution judgment incorporated a separation agreement and parenting plan. The plan included a handwritten provision that the Regional Family Trial Docket (RFTD) "shall retain jurisdiction" over future custody/parenting disputes.
In January 2020 the defendant filed a contempt motion and a motion to appoint a guardian ad litem (GAL). The plaintiff filed multiple emergency/ex parte custody motions from January through August 2020 seeking limitations on the defendant's access to the children and their records.
On September 14, 2020 the plaintiff moved to transfer adjudication of the postjudgment disputes to the RFTD. At the September 17, 2020 hearing the trial court denied the transfer (stating RFTD would not accept the case), appointed a GAL by agreement of the parties, and set a fee/duties hearing for October 8, 2020.
The plaintiff filed an appeal on September 28, 2020 challenging the September 17 orders (and later amended to challenge additional related interlocutory orders). No final resolution had been entered on the contempt or modification/visitation motions when the appeal was filed.
The Appellate Court ordered memoranda on appealability and, on December 16, 2020, dismissed the appeal for lack of jurisdiction. The court held the September 17 orders were interlocutory and did not satisfy either prong of the State v. Curcio test.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court's denial of transfer to the RFTD is immediately appealable	Ricketts contends the divorce decree (separation agreement) gives a contractual right to have future custody issues heard in the RFTD, allowing immediate appeal	Trial court's denial was entered during ongoing postjudgment proceedings, did not terminate any separate proceeding, and is interlocutory	Denial is interlocutory; does not satisfy Curcio prongs; appeal dismissed for lack of jurisdiction
Whether appointment of a guardian ad litem is immediately appealable	Plaintiff disputed the court's finding that he agreed to the GAL appointment and challenged the appointment	Appointment is an investigatory step under §46b-54 toward resolving custody/visitation/education issues and does not resolve rights finally	Appointment is interlocutory and not immediately appealable under Curcio; appeal dismissed

State v. Curcio, 191 Conn. 27 (Conn. 1983) (establishes two‑prong test for when interlocutory orders are immediately appealable)
Khan v. Hillyer, 306 Conn. 205 (Conn. 2012) (discusses final judgment requirement for appellate jurisdiction)
Kennedy v. Kennedy, 109 Conn. App. 591 (Conn. App. 2008) (appointment of counsel/GAL in postjudgment custody proceedings is a step toward final judgment and not immediately appealable)
McGuinness v. McGuinness, 155 Conn. App. 273 (Conn. App. 2015) (applies Curcio to postjudgment family matters)
Heyward v. Judicial Dept., 159 Conn. App. 794 (Conn. App. 2015) (orders transferring cases during ongoing litigation are not appealable under Curcio)
Soracco v. Williams Scotsman, Inc., 128 Conn. App. 818 (Conn. App. 2011) (contractual rights alone do not satisfy Curcio's second prong)