Morales v. Meehan

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Morales v. Meehan

MARIBEL MORALES v. ROBERT F. MEEHAN
(AC 47967)
Elgo, Clark and Westbrook, Js.

Syllabus

The defendant, whose marriage to the plaintiff previously had been dissolved,
appealed from the trial court’s judgment granting the plaintiff’s postjudg-
ment motions for contempt. The defendant claimed, inter alia, that the court
violated his right to procedural fairness by denying him the opportunity to
testify at the hearing on one of the plaintiff’s motions. Held:
The defendant’s claim that the trial court violated his right to procedural
fairness was without merit, as the record indicated that the defendant agreed
to have the court decide the plaintiff’s postjudgment motion for contempt
on the basis of the record of a previous hearing, and there was no indication
in the record that the defendant ever objected to that course of action or
requested an opportunity to testify further or to present additional evidence
in connection with that motion.
This court declined to review the merits of the defendant’s claim that the
trial court erred in finding that he had been difficult and uncooperative with
professionals involved with the family, as the defendant failed to provide a
transcript of the hearing on which the court based its findings, thus, the
record was inadequate for review.
This court declined to review the defendant’s unpreserved claim that his
right to procedural due process was violated by the plaintiff’s failure to
disclose certain materials in a timely manner, as he did not raise the issue
before the trial court.
The trial court properly granted the plaintiff’s motion for contempt regard-
ing the marital property dissolution order, as the evidence in the record
supported the court’s conclusion that the plaintiff established by clear and
convincing evidence that the defendant wilfully violated the court’s order.
This court declined to review the defendant’s claim that the trial court
improperly found him in contempt when the record demonstrated that the
plaintiff failed to exercise a “self-executing remedy,” as the defendant failed
to adequately brief this claim.
The defendant’s claim that the trial court improperly modified the property
distribution orders by appointing a committee to sell the marital residence
after finding the defendant in contempt was unavailing, as the court’s order
of relief was a proper exercise of its remedial contempt authority to effectu-
ate the terms of the judgment of dissolution.

Argued February 19—officially released June 9, 2026

Procedural History

Action for the dissolution of a marriage, and for other
relief, brought to the Superior Court in the judicial dis-
Morales v. Meehan

trict of Stamford-Norwalk, where the defendant filed
a cross complaint; thereafter, the case was tried to the
court, Hon. Gerald I. Adelman, judge trial referee; judg-
ment dissolving the parties’ marriage and issuing certain
orders; subsequently, the court, Tindill, J., rendered
judgment granting the plaintiff’s postjudgment motions
for contempt, from which the defendant appealed to this
court. Affirmed.
Robert F. Meehan, self-represented, the appellant
(defendant).

Opinion

ELGO, J. The self-represented defendant, Robert F.
Meehan,1 appeals from the judgment of the trial court
granting two postjudgment motions for contempt filed
by the plaintiff, Maribel Morales.2 On appeal, the defen-
dant raises a bevy of claims regarding the court’s deci-
sion to find him in contempt of the court’s custody and
parenting orders and the court’s property distribution
orders regarding the marital residence. We affirm the
judgment of the trial court.
The record discloses the following undisputed facts.
The parties married in 2003, and one child was born of
the marriage. Following the subsequent breakdown of the
marriage, the plaintiff commenced a dissolution action
in 2016. After a period of attempted reconciliation,
the defendant filed an answer and a cross complaint in
2018, and a six day trial followed. On February 11, 2020,
the court, Hon. Gerald I. Adelman, judge trial referee,
rendered judgment dissolving the parties’ marriage.
As part of the judgment of dissolution, the court made
numerous factual findings and entered detailed custody
1
The defendant was represented by legal counsel before the trial court
and appears in a self-represented capacity in this appeal.
2
The plaintiff appeared, but has not participated, in this appeal.
Because she did not file an appellate brief, we ordered that the appeal
shall be considered on the basis of the defendant’s brief and appendix,
the record, and the defendant’s oral argument. See, e.g., Ammar I. v.
Evelyn W., 227 Conn. App. 827, 830 n.2, 323 A.3d 1111 (2024).
Morales v. Meehan

and parenting orders regarding the minor child. The
court also entered orders regarding the parties’ mari-
tal residence at 50 Havemeyer Lane in Old Greenwich.3
Specifically, it ordered the plaintiff to quitclaim her
interest in the marital residence to the defendant and
ordered the defendant to execute a mortgage note and
deed in favor of the plaintiff in the amount of $183,000
to be paid on or before March 1, 2023 (plaintiff’s mort-
gage). The court also ordered that the defendant “shall
be solely liable for all costs and expenses associated with
the ownership and possession of the [marital residence]
. . . .” In addition, the court ordered that, if the defen-
dant failed to pay the plaintiff’s mortgage by March 1,
2023, the marital residence would be sold pursuant to
“an aggressive marketing plan, designed to achieve a
sale as quickly as possible . . . .” It is undisputed that a
quitclaim deed from the plaintiff and a mortgage deed
and promissory note from the defendant subsequently
were filed on the Greenwich land records.4
On March 1, 2023, the plaintiff filed a postjudgment
motion for contempt, in which she alleged, inter alia, that
the defendant had failed to pay the plaintiff’s mortgage
in violation of the court’s property distribution orders.
On November 13, 2023, the plaintiff filed a motion for
the appointment of a guardian ad litem for the parties’
minor child. The court granted that motion and, with
the agreement of the parties, appointed Attorney Paul
Tusch as guardian ad litem. On November 15, 2023, the
plaintiff filed another postjudgment motion for con-
tempt, in which she alleged that the defendant had failed
to comply with the court’s custody and parenting orders.
3
In its memorandum of decision, the court found that the marital
residence had a fair market value of $855,000 and was encumbered by
a $461,095 mortgage, “leaving an estimated equity of $393,905 . . . .”
4
The promissory note stated in relevant part: “For value received
the [defendant] does promise to pay to the order of [the plaintiff] the
principal sum of [$183,000] on or before March 1, 2023. The principal
sum shall bear no interest until March 1, 2023, but if unpaid as of that
date shall commence and continue to earn interest at the rate of ten
percent (10%) per annum until paid in full. . . .”
Morales v. Meehan

The court held separate evidentiary hearings on those
contempt motions. It thereafter granted both contempt
motions, and this appeal followed.
Before considering the specific claims advanced by the
defendant, we note certain principles relevant to this
appeal. “[C]ivil contempt is committed when a person
violates an order of court which requires that person in
specific and definite language to do or refrain from doing
an act or series of acts. . . . To constitute contempt, it
is not enough that a party has merely violated a court
order; the violation must be wilful. . . . It is the burden of
the party seeking an order of contempt to prove, by clear
and convincing evidence, both a clear and unambiguous
directive to the alleged contemnor and the alleged con-
temnor’s wilful noncompliance with that directive. . . .
The question of whether the underlying order is clear and
unambiguous is a legal inquiry subject to de novo review.
. . . If we answer that question affirmatively, we then
review the trial court’s determination that the violation
was wilful under the abuse of discretion standard.” (Cita-
tions omitted; internal quotation marks omitted.) Puff
v. Puff, 334 Conn. 341, 364–66, 222 A.3d 493 (2020);
see also Ramin v. Ramin, 281 Conn. 324, 336, 915 A.2d
790 (2007) (“the abuse of discretion standard applies to
a trial court’s decision on a motion for contempt”).
I
We first address the defendant’s claims pertaining to
the court’s decision to grant the plaintiff’s November
15, 2023 motion for contempt. The defendant contends
that (1) the court violated his right to “procedural fair-
ness” by denying him the opportunity to testify at the
contempt hearing on that motion, (2) the court errone-
ously found that the defendant had been difficult and
uncooperative with professionals, and (3) his right to
procedural due process was violated by the plaintiff’s
failure to disclose certain transcripts and audio record-
ings in a timely manner.
Morales v. Meehan

The following additional facts are relevant to those
claims. On December 21, 2023, the court, Hon. Michael
E. Shay, judge trial referee, held a hearing on various
postdissolution motions filed by the parties. Although
the plaintiff’s motions for contempt were mentioned at
that hearing, their substance was not discussed. As that
hearing concluded, the court observed that the “custody
related” issues raised in the plaintiff’s November 15,
2023 motion for contempt were “the ones that need to
be addressed. They need to be addressed first. They will
be the ones that are going to be addressed first [at a hear-
ing] in January.” The court thereafter held a hearing
on that contempt motion and other unrelated motions
on January 18, 2024.
This court takes judicial notice of the undisputed fact
that Judge Shay’s term as a judge trial referee in this
state concluded in February 2024. See, e.g., Parsons v.
United Technologies Corp., 243 Conn. 66, 84–85 n.18,
700 A.2d 655 (1997) (taking judicial notice of undisputed
events that were “capable of ready and unquestionable
demonstration”). On February 28, 2024, the court,
Heller, J., held a hearing with the parties and the guard-
ian ad litem. At the outset, the court acknowledged that
Judge Shay was “no longer on the bench.” The court then
indicated that it “unfortunately” would have to order
a mistrial on the motions that had been the subject of
the January 18, 2024 hearing. The court further noted
that “[t]here is a statute that [permits] the court, if a
judge retires, to pick it up and finish” a pending mat-
ter. In response, the plaintiff’s attorney stated in rel-
evant part: “[At the January 18, 2024 hearing], we had
started with [the plaintiff’s November 15, 2023 motion
for contempt] and . . . I had concluded my presentation
of our motion. . . . [A]ll the testimony that I intended to
elicit [on the plaintiff’s November 15, 2023 motion for
contempt] has been elicited. All the exhibits I wanted to
be presented have been admitted into evidence. I would
have no objection to whatever successor judge takes over
the balance of the case that they rely on the transcript
and the exhibits; again, this is [the November 15, 2023
Morales v. Meehan

motion for contempt]. If [the defendant] chooses not
to testify, that’s fine. It could really be decided on the
papers. If he decides to testify, that judge can hear
that and then make that ruling. . . . [W]e spent I think
virtually all day on [the November 15, 2023 motion for
contempt] and to have to go through that again, again
I am willing to have [the] successor judge rely on the
transcript and the exhibits . . . and then complete the
rest of our motions with [the] successor judge.” The
court then stated: “[T]hat’s helpful and as I said there is a
statute that does provide for a successor judge to pick up
when a hearing is concluded. Here we may still be in the
middle of a hearing but if there is no objection obviously
the judge could take that. . . . So, what I am going to do
[is] I am going to reserve on declaring a mistrial on [the
plaintiff’s November 15, 2023 motion for contempt].”5
By order dated February 28, 2024, the court declared
a mistrial on certain motions heard at the January 18,
2024 hearing before Judge Shay. With respect to the
plaintiff’s November 15, 2023 motion for contempt,
the court deferred “the entry of a mistrial . . . until a
successor judge has determined whether to proceed on
the existing record and conclude the hearing pursuant
to General Statutes § 51-183f.”
On April 10, 2024, the court, Tindill, J., held a confer-
ence with the parties. In an order issued later that day,
the court stated that “[t]he parties agree that the court
will review the record of the [January 18, 2024 hearing]
and rule on the plaintiff’s [November 15, 2023] postjudg-
ment motion for contempt.” The court further indicated
that a hearing on the other pending motions, including
the plaintiff’s March 1, 2023 motion for contempt, was
scheduled for late June.
5
The defendant raised no objection at that time. The transcript of the
February 28, 2024 hearing indicates that the court specifically asked the
defendant’s counsel if he wanted to be heard on that issue and counsel
responded: “No, Your Honor, other than, you know, unfortunately these
things have been ticking around a long time and as soon as we could get
[before the successor judge] that would be greatly appreciated.”
Morales v. Meehan

On June 20, 2024, the court issued an order granting
the plaintiff’s November 15, 2023 motion for contempt.
In that order, the court first noted that “[t]he parties
and their counsel appeared before [Judge Shay] on Janu-
ary 18, 2024, to prosecute the plaintiff’s [November
15, 2023] postjudgment motion for contempt. Both
parties testified, as did the guardian ad litem . . . .”
The court explained that its “orders and findings” were
based on, inter alia, the court’s “review of the record of
the January 18, 2024 proceedings” and “[t]he parties’
consent to the court’s review and issuance of a ruling,”
in accordance with the court’s April 10, 2024 order. The
court then proceeded to find that the custody and parent-
ing orders in question were clear and unambiguous and
that the defendant had wilfully violated those orders
by “with[holding] the child from the plaintiff without
good cause from October 14, 2023, to December 14,
2023,” by keeping “information from the plaintiff and
ma[king] unilateral decisions regarding the minor child
in the fall and winter of 2023,” and by “undermin[ing]
the plaintiff as the child’s parent.” In that order, the
court also found that “[t]he defendant is difficult—he
does not cooperate with professionals involved with the
family.” Although the record before us indicates that
the defendant has filed multiple postjudgment motions
seeking reargument, reconsideration, and articulation
with the trial court regarding various rulings, he did not
file any such motion with respect to its June 20, 2024
ruling on the plaintiff’s November 15, 2023 motion for
contempt.
A
On appeal, the defendant claims that the court vio-
lated his right to “procedural fairness” by denying him
the opportunity to testify at the contempt hearing and
“fully present [his] evidence.” The record belies that
contention.
The record indicates that, in February 2024, the court
held a hearing following Judge Shay’s retirement from
Morales v. Meehan

the bench. At that hearing, the plaintiff’s counsel
averred that the plaintiff had finished presenting its
evidence on the November 15, 2023 motion for contempt
at the January 18, 2024 hearing before Judge Shay and
that, “at the end of the day [the defendant’s] counsel said
[he] will need to confer with [the defendant] as to whether
or not he would want to testify” as part of his case. The
court then stated that it would reserve judgment on
whether to grant a mistrial on that motion for contempt
and would allow the parties an opportunity to reach an
“agreement” as to how to proceed on that motion before
a successor judge. At that time, the defendant raised no
objection. See footnote 5 of this opinion.
The record also indicates that the successor judge sub-
sequently held a conference with the parties on April 10,
2024. After that conference concluded, the court issued
an order in which it stated in relevant part: “The parties
agree that the court will review the record of the [January
18, 2024 hearing] and rule on the plaintiff’s [November
15, 2023] postjudgment motion for contempt.”
On appeal, the defendant neither acknowledges that
order of the court nor challenges its substance in any
manner. The court’s April 10, 2024 order speaks for
itself and indicates that the defendant agreed to have
the court decide the plaintiff’s November 15, 2023 post-
judgment motion for contempt on the basis of the record
of the January 18, 2024 hearing. Moreover, there is no
indication in the record that the defendant ever objected
to that course of action or requested an opportunity to
testify further or present additional evidence in con-
nection with that motion for contempt. In light of the
foregoing, we conclude that the defendant’s procedural
fairness claim is without merit.
B
The defendant also claims that, in its June 20, 2024
order granting the plaintiff’s motion for contempt, the
court erroneously found that he had been “difficult” and
Morales v. Meehan

uncooperative with “professionals involved with the
family.” We decline to review the merits of that claim.
It is axiomatic that “[t]he trial court’s findings [of
fact] are binding upon this court unless they are clearly
erroneous in light of the evidence and the pleadings in the
record as a whole. . . . A finding of fact is clearly errone-
ous when there is no evidence in the record to support it
. . . or when although there is evidence to support it, the
reviewing court on the entire evidence is left with the
definite and firm conviction that a mistake has been com-
mitted.” (Internal quotation marks omitted.) Steller v.
Steller, 181 Conn. App. 581, 588, 187 A.3d 1184 (2018);
see also Jacob-Dick v. Dick, 231 Conn. App. 404, 412,
333 A.3d 210 (2025) (“[w]e review the factual findings
that underlie a court’s contempt determination pursuant
to the clearly erroneous standard”).
In its June 20, 2024 order granting the plaintiff’s
motion for contempt, the court expressly stated that its
factual findings were predicated on, inter alia, its “review
of the record” of the January 18, 2024 hearing before
Judge Shay. Although the defendant has furnished this
court with transcripts of other trial court proceedings,
consistent with his obligation as an appellant; see Prac-
tice Book § 63-8 (a); the defendant has not provided the
transcript of the January 18, 2024 hearing. Moreover,
that transcript is not contained in the record before
us. We therefore are unable to review the record of the
January 18, 2024 hearing to determine whether the
factual findings in question are clearly erroneous. See,
e.g., Taylor v. American Thread Co., 200 Conn. 108,
112, 509 A.2d 512 (1986) (“[w]ithout the appropriate
transcripts to provide us a record of what transpired
at trial, we cannot . . . find error in the judgment of the
trial court”); Buggy v. Buggy, 141 Conn. App. 733, 737,
64 A.3d 778 (2013) (“[w]here a transcript is required
for review of a party’s claims, this court cannot pro-
ceed without one”). Because the record is inadequate to
review the defendant’s challenge to the factual findings
Morales v. Meehan

contained in the court’s June 20, 2024 order, we decline
to review that claim.
C
The defendant also claims that his right to procedural
due process was violated by the plaintiff’s failure to dis-
close certain materials in a timely manner. Specifically,
he claims that the plaintiff “submitted transcripts and
audio recordings from a January 18, 2024 hearing to
her attorney ex parte” that allegedly were not furnished
to the defendant “until June 25, 2024, creating a due
process violation.” To the extent that the defendant
articulates a cognizable claim, we nonetheless conclude
that it is unpreserved.
Our rules of practice require a party, as a prerequisite
to appellate review, to distinctly raise its claim before
the trial court. See Practice Book § 5-2 (“[a]ny party
intending to raise any question of law which may be the
subject of an appeal must . . . state the question distinctly
to the judicial authority”); Practice Book § 60-5 (“[t]he
court shall not be bound to consider a claim unless it was
distinctly raised at the trial or arose subsequent to the
trial”). For that reason, we repeatedly have held that “we
will not decide an issue that was not presented to the trial
court. To review claims . . . not raised before the trial
court would be nothing more than a trial by ambuscade
of the trial judge.” (Internal quotation marks omitted.)
State v. Martin, 110 Conn. App. 171, 180, 954 A.2d 256
(2008), appeal dismissed, 295 Conn. 192, 989 A.2d 1072
(2010); see also State v. Jorge P., 308 Conn. 740, 753,
66 A.3d 869 (2013) (“the sina qua non of preservation
is fair notice to the trial court”); State v. Favoccia, 119
Conn. App. 1, 14, 986 A.2d 1081 (2010) (“[i]t is axiom-
atic that issues not properly raised before the trial court
ordinarily will not be considered on appeal”), aff’d, 306
Conn. 770, 51 A.3d 1002 (2012).
The defendant has not identified, nor can we uncover,
anywhere in the record that he raised his procedural
due process claim before the trial court. That claim,
Morales v. Meehan

therefore, is unpreserved. Moreover, the defendant has
not sought review pursuant to State v. Golding, 213
Conn. 233, 239–40, 567 A.2d 823 (1989), as modified
by In re Yasiel R., 317 Conn. 773, 781, 120 A.3d 1188
(2015), and cannot prevail under its first prong. The
defendant has not provided this court with an adequate
record to review such a claim, as the “transcripts and
audio recordings” he references in his appellate brief
are not in the record before us and he has not identified
anywhere in the record that the issue of his access to
those materials is discussed. The defendant, therefore,
is not entitled to Golding review. See State v. Elson, 311
Conn. 726, 755, 91 A.3d 862 (2014). Accordingly, we
decline to review that unpreserved constitutional claim.6
II
We next consider the defendant’s claims regarding
the court’s decision to grant the plaintiff’s March 1,
2023 motion for contempt. The defendant claims that
the court improperly (1) concluded that he wilfully vio-
lated the property distribution orders regarding the
marital residence, (2) found him in contempt when the
record demonstrates that the plaintiff failed “to exercise
a self-executing remedy,” and (3) modified the property
distribution orders by ordering a committee to sell the
property. We do not agree.
6
We likewise decline to review the merits of two nonconstitutional
claims that concern a report allegedly prepared by the Department of
Children and Families. In his appellate brief, the defendant claims
that “the guardian ad litem failed to investigate or present a 137 page
Department of Children and Families report documenting allegations
of violence by the plaintiff towards the [minor] child,” which allegedly
“raises concerns about the adequacy of the [guardian ad litem’s] repre-
sentation.” The defendant relatedly claims that the trial court failed
to consider that report in ruling on the plaintiff’s November 15, 2023
postjudgment motion for contempt. The record before us indicates that
the defendant did not distinctly raise either of those claims before the
trial court. We therefore decline to address them. See, e.g., Torres
v. Waterbury, 249 Conn. 110, 134, 733 A.2d 817 (1999) (declining
to review claim that “was not distinctly raised or decided at the trial
level”); DiGiuseppe v. DiGiuseppe, 174 Conn. App. 855, 864, 167 A.3d
411 (2017) (declining to review claim “because it was not distinctly
raised at the contempt hearing”).
Morales v. Meehan

A
In its August 14, 2024 order on the plaintiff’s March
1, 2023 motion for contempt, the court found that the
defendant wilfully violated the dissolution order that
required him to pay the plaintiff’s mortgage on or before
March 1, 2023. On appeal, the defendant challenges the
propriety of that determination.7
In its order, the court specifically found that “[t]he
defendant did not pay the [plaintiff’s mortgage] on or
before March 1, 2023.” That factual finding is not con-
tested by the defendant on appeal. The court further
found that the plaintiff had met her burden of establish-
ing, by clear and convincing evidence, that the defendant
wilfully violated the dissolution order that required such
payment. At the hearing on the plaintiff’s March 1, 2023
motion for contempt, the defendant acknowledged that
the court’s dissolution orders required him to pay “the
sum of $183,000” to the plaintiff on or before March 1,
2023, in satisfaction of the plaintiff’s mortgage. The
defendant also confirmed that he had three years to
pay off the plaintiff’s mortgage but did not do so. The
defendant offered no explanation for his failure to comply
with that property distribution order.
The defendant likewise confirmed that no documentary
evidence existed to indicate that he attempted to refi-
nance the existing mortgage on the property in order to
fulfill his obligation to pay the plaintiff’s mortgage. The
court also was presented with evidence that, although
the defendant listed the marital residence for sale in
early 2023, he subsequently cancelled that listing. In
addition, the plaintiff adduced evidence at the hearing
demonstrating that the defendant repeatedly told the
minor child, both verbally and through text messages,
that he did not want to move out of the marital residence
and was going to do everything he could to stay in that
7
The defendant does not challenge the propriety of the court’s deter-
mination that the dissolution order requiring him to pay the plaintiff’s
mortgage by March 1, 2023, “is a clear and unambiguous court order.”
Morales v. Meehan

residence. Later in his testimony, the following colloquy
transpired:
“The Court: So, as you sit here today, you have no
intention of selling the home because you’d like to try
to keep [the minor child] in it?
“The Defendant: Yes.
“The Court: Okay. And you are not disputing the fact
that that is contrary to the court order?
“The Defendant: I’m not. . . .
“The Court: It sounds like come hell or high water what
you would like to do is keep your daughter in that home,
period, end of story.
“The Defendant: Until she finishes school.
“The Court: Got it. Okay.”
That testimony supports the court’s finding that the
defendant “did not make a good faith effort to sell” the
marital residence.
In light of the foregoing, we conclude that the evidence
in the record before us substantiates the court’s conclu-
sion that the plaintiff established by clear and convincing
evidence that the defendant wilfully violated the court’s
dissolution order requiring him to pay the plaintiff’s
mortgage on or before March 1, 2023.
B
The defendant also claims that the court improperly
found him in contempt when the record demonstrates
that the plaintiff failed to exercise a “self-executing rem-
edy” following his failure to pay the plaintiff’s mortgage
by March 1, 2023. More specifically, he maintains that
“a party cannot be held in contempt when their alleged
failure to act stems from the other party’s failure to
exercise a self-executing remedy.”
The defendant has failed to adequately brief that bald
assertion. His briefing on this claim consists of two
Morales v. Meehan

sentences8 and a citation to a single case; Maguire v.
Maguire, 222 Conn. 32, 608 A.2d 79 (1992); that does not
involve a contempt proceeding and does not contain any
reference to, or discussion of, “self-executing” remedies.
As our Supreme Court has observed, the appellate courts
of this state “are not required to review issues that have
been improperly presented . . . through an inadequate
brief. . . . Analysis, rather than mere abstract assertion,
is required in order to avoid abandoning an issue by
failure to brief the issue properly. . . . [When] a claim is
asserted in the statement of issues but thereafter receives
only cursory attention in the brief without substantive
discussion or citation of authorities, it is deemed to be
abandoned.” (Internal quotation marks omitted.) Cohen
v. Rossi, 346 Conn. 642, 689, 295 A.3d 75 (2023); see
also Russell v. Russell, 91 Conn. App. 619, 635, 882
A.2d 98 (parties must analyze relationship between facts
of case and applicable law), cert. denied, 276 Conn. 925,
888 A.2d 92 (2005), and cert. denied, 276 Conn. 924,
888 A.2d 92 (2005). We, therefore, decline to review
the defendant’s inadequately briefed claim.
C
As a final matter, the defendant claims that the court
improperly modified the property distribution orders
by appointing a committee to sell the marital residence
after finding the defendant in contempt. We disagree.
The following additional facts are relevant to that
claim. In its memorandum of decision dissolving the par-
ties’ marriage, the court entered various orders regard-
ing the marital residence, including one obligating the
defendant to pay the plaintiff’s mortgage by March 1,
2023. The court further ordered that, if the defendant
failed to pay the plaintiff’s mortgage by that date, the
8
The defendant’s appellate brief states: “The plaintiff failed to exercise
her explicit remedy under the memorandum of decision, which allowed
her to initiate a sale of the property if [the plaintiff’s mortgage] was
not paid by March 1, 2023. Connecticut law holds that a party cannot
be held in contempt when their alleged failure to act stems from the
other party’s failure to exercise a self-executing remedy.”
Morales v. Meehan

marital residence would be sold pursuant to “an aggres-
sive marketing plan, designed to achieve a sale as quickly
as possible . . . .” The court then outlined the mechanism
by which such a sale would occur.9
Although that mechanism permitted the plaintiff to
select a real estate agent to set an asking price and list
the marital residence for sale if the defendant did not pay
the plaintiff’s mortgage by March 1, 2023, the record
unequivocally indicates that the property already was
listed for sale at that time. At the contempt hearing, the
defendant testified that he placed the marital residence
on the market for sale in early 2023. The marital resi-
dence remained on the market until August 29, 2023.10
9
The court ordered as follows: “If [the plaintiff’s mortgage] is not
paid on or before March 1, 2023, [the marital residence] is to be sold
pursuant to the sale provisions outlined below, said sale shall be based
on an aggressive marketing plan, designed to achieve a sale as quickly
as possible;
“a. The plaintiff shall pick the real estate agent to handle the market-
ing of the property;
“b. The selected agent shall set the asking price and the parties are
to accept any legitimate offer within five percent of the asking price;
“c. Said price shall be reduced by ten percent every sixty days, so long
as the listed price is not so low as to require a ‘short sale’;
“d. If there is a sale, the parties shall be equally responsible for the
payoff of the mortgage, the real estate commissions, the conveyance
taxes and recording fees; The defendant shall be solely liable for the real
estate taxes, utility bills and cost of any repairs or deferred maintenance
required to have the real property ready for sale;
“e. Any net proceeds from said sale after the plaintiff is paid her share
and any interest that may have accumulated, all remaining proceeds
shall belong solely to the defendant;
“f. The court shall retain jurisdiction over the real property until this
order has been carried out in full . . . .”
10
A copy of the listing agreement between the defendant and Berkshire
Hathaway Home Services New England Properties was admitted into
evidence at the contempt hearing as a full exhibit. That document speci-
fies a listing date of February 2, 2023. It also contains an “amendment
listing agreement” signed by the defendant and dated August 29, 2023,
which states in relevant part that “[t]he above referenced Listing or
Right to Sell Agreement is amended in the following ways . . . [l]isting
cancellation, and withdraw from the [multiple listing service].” In
addition, that exhibit contains a “listing change form” dated August 29,
2023, that is signed by the defendant and the managing broker, which
specifies that the defendant had withdrawn and cancelled the listing.
Morales v. Meehan

Accordingly, the property was actively listed for sale
in March, 2023, when the plaintiff’s right to select an
agent and place the property on the market arose pursu-
ant to the court’s dissolution orders. See footnote 9 of
this opinion.
In light of the foregoing, the plaintiff filed a motion
for contempt on March 1, 2023, in which she alleged that
the defendant had failed to pay the plaintiff’s mortgage
and requested, inter alia, an order “compelling immedi-
ate compliance with the court orders” regarding the sale
of the marital residence. At the subsequent hearing on
that motion, the plaintiff testified that she had selected
a real estate broker to handle the sale of the property
in anticipation of a favorable ruling from the court.
Later in her testimony, the court specifically asked the
plaintiff what relief she wanted if the court was to find
the defendant in contempt. The plaintiff responded
that she wanted to recover “whatever is owed to me, per
[the court’s dissolution] order.” The court then asked
the plaintiff whether she preferred to have a real estate
agent list the property for sale or have the court order
its sale, to which the plaintiff clarified that she just
wanted the property sold so that she could recover her
share of the proceeds in accordance with the property
distribution orders.
The court subsequently granted the plaintiff’s motion
for contempt, finding that the defendant wilfully vio-
lated the dissolution order by not paying the plaintiff’s
mortgage by March 1, 2023. The court then ordered
in relevant part: “In light of the defendant’s refusal to
comply with the orders regarding the sale of the [marital
residence], it is hereby ordered that the property . . . be
sold by committee. . . . Fees and expenses of the com-
mittee shall be paid from the net proceeds of the sale
after satisfaction of the plaintiff’s mortgage . . . plus
10 percent interest per annum . . . .”
On appeal, the defendant claims that the foregoing
order constitutes an improper modification of the court’s
property distribution orders. We do not agree. In the
Morales v. Meehan

February 11, 2020 judgment of dissolution, the court
specifically stated in its orders regarding the marital
residence that “[t]he court shall retain jurisdiction over
[that] property until this order has been carried out in
full . . . .” At the contempt hearing, the court was pre-
sented with uncontroverted testimony and documen-
tary evidence indicating that the marital residence was
actively listed for sale on the terminal date of March 1,
2023. The court at that hearing also received clarifica-
tion from the plaintiff that her sole aim in pursuing this
motion for contempt was to recover the sums due under
the property distribution orders, which plainly entitled
her to $183,000 along with interest accrued after March
1, 2023. In securing that relief for the plaintiff, the court
ordered the sale of the marital residence by committee.
In light of the particular circumstances of the present
case, we cannot conclude that the court’s decision to do so
was improper. “A court . . . does not have the authority
to modify the division of property once the dissolution
becomes final. . . . Although the court does not have the
authority to modify a property assignment, a court . . .
does have the authority to issue postjudgment orders
effectuating its judgment.” (Emphasis in original; inter-
nal quotation marks omitted.) Schneider v. Schneider,
161 Conn. App. 1, 6, 127 A.3d 298 (2015). The property
assignment here awarded the defendant the marital
residence, subject to an obligation to pay the plaintiff
a specific sum secured by a mortgage and promissory
note. In the event that the defendant failed to make that
payment, the judgment of dissolution contemplated a
prompt sale of the marital residence to ensure that the
plaintiff recovered that sum. In our view, the court’s
decision to order a committee sale of the property fol-
lowing the contempt hearing was simply an attempt to
effectuate those dissolution orders.
As this court has observed, the trial court “has author-
ity to order additional measures not contained in the
original order if they are necessary to effectuate the
original judgment.” (Internal quotation marks omitted.)
Morales v. Meehan

Behrns v. Behrns, 124 Conn. App. 794, 822, 6 A.3d
184 (2010); see also Roberts v. Roberts, 32 Conn. App.
465, 471–72, 629 A.2d 1160 (1993) (order to auction
property effectuated original judgment despite fact that
dissolution judgment did not call for sale by auction).
We therefore conclude that the court’s order of relief
in the present case was a proper exercise of its remedial
contempt authority to effectuate the terms of the judg-
ment of dissolution.
The judgment is affirmed.
In this opinion the other judges concurred.