Sorrentino v. Sorrentino, 160 Conn.App. 25

Parties divorced in 2007; the dissolution judgment incorporated a May 30, 2007 joint parenting plan giving Kathryn (mother) physical custody and Saverio (father) liberal/holiday/vacation visitation.
On April 15, 2010 Judge Pinkus held a modification hearing (father absent) and issued a limited order changing weekend visitation to Saturdays 1–5 p.m. and Sundays 3–6 p.m.; no discussion of holiday or vacation visitation occurred at that hearing.
Father later filed a contempt motion (May 2013) alleging mother denied him holiday and vacation parenting time and excluded him from decisions about the children.
On November 8, 2013 Judge Klatt held a contempt hearing, appointed a guardian ad litem, and expressly ruled the April 15, 2010 order did not modify the May 2007 parenting plan’s holiday/vacation provisions; he ordered compliance with the 2007 plan for the upcoming holiday.
Subsequent proceedings (March–May 2014) resulted in the court finding mother in contempt, adopting the guardian ad litem’s recommendations, and ultimately awarding father sole legal and physical custody on May 23, 2014.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the April 15, 2010 order modified father’s holiday/vacation visitation under the May 2007 parenting plan	Father argued the April 15, 2010 order was limited to weekend times and did not affect holiday/vacation rights (so the 2007 plan controls)	Mother argued the April 15, 2010 order modified all of father’s visitation, including holidays and vacations	The court held the April 15, 2010 order did not modify holiday/vacation visitation; the 2007 parenting plan’s holiday schedule remained in effect
Whether the appeal of the Nov. 8, 2013 order is justiciable (mootness/jurisdiction)	Father implicitly argued relief unnecessary because custody later changed; court considered jurisdiction	Mother sought review of the Nov. 8, 2013 order reinstating 2007 holiday schedule	The appellate court dismissed the appeal as to the Nov. 8, 2013 order as moot because father was later awarded sole custody; no practical relief available

Kennedy v. Kennedy, 109 Conn. App. 591 (discussing mootness and appellate jurisdiction)
State v. Charlotte Hungerford Hospital, 308 Conn. 140 (describing mootness as precluding practical appellate relief)
Loisel v. Rowe, 233 Conn. 370 (explaining the "capable of repetition, yet evading review" mootness exception)
Clelford v. Bristol, 150 Conn. App. 229 (appellate review limits where issues are inadequately briefed)