Bowens v. Administrator, Unemployment Compensation Act

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Bowens v. Administrator, Unemployment Compensation Act

PAMELA BOWENS v. ADMINISTRATOR,
UNEMPLOYMENT COMPENSATION
ACT, ET AL.
(AC 47683)
Cradle, C. J., and Elgo and Moll, Js.

Syllabus

The defendant administrator of the Unemployment Compensation Act, who
had determined that the plaintiff was ineligible for unemployment benefits,
appealed from the trial court’s decision remanding the plaintiff’s unemploy-
ment compensation action to the Board of Review of the Employment
Security Appeals Division for reconsideration by its appeals referee of the
decision denying the plaintiff’s motion to open the referee’s decision dismiss-
ing her appeal as untimely. The defendant claimed, inter alia, that the court
exceeded its limited scope of judicial review in making factual findings and
in substituting its judgment for that of the board. Held:

The trial court improperly exceeded its limited scope of judicial review by
finding facts beyond those contained in the certified record and by relying
on its improper findings in examining the board’s decision, and, on the basis
of the controlling factual findings set forth in the certified record, this court
could not conclude that the board acted unreasonably, arbitrarily, illegally,
or in abuse of its discretion in affirming the referee’s denial of the motion
to open.

Argued November 17—officially released December 30, 2025

Procedural History

Appeal from the decision of the Board of Review of
the Employment Security Appeals Division affirming
the decision of its referee denying the plaintiff’s motion
to open the referee’s decision dismissing her appeal
from the named defendant’s decision determining that
she was ineligible for unemployment benefits, brought
to the Superior Court in the judicial district of Water-
bury and tried to the court, Cordani, J.; judgment
remanding the case to the referee for reconsideration,
from which the named defendant appealed to this court.
Reversed; judgment directed.
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Richard T. Sponzo, assistant attorney general, with
whom, on the brief, was William Tong, attorney gen-
eral, for the appellant (named defendant).
Pamela Bowens, self-represented, the appellee
(plaintiff).
Opinion

MOLL, J. The defendant Administrator of the Unem-
ployment Compensation Act1 appeals from the judg-
ment of the Superior Court rendered in the administra-
tive appeal filed by the self-represented plaintiff,
Pamela Bowens, from the decision of the Board of
Review of the Employment Security Appeals Division
(board). The board affirmed the decision of the referee
at the Employment Security Appeals Division (referee)
denying, as untimely, the plaintiff’s motion to open the
referee’s decision dismissing, as untimely, her appeal
from the defendant’s decision determining that she was
ineligible for unemployment benefits. In the administra-
tive appeal, the Superior Court remanded the matter for
reconsideration of the referee’s denial of the plaintiff’s
motion to open. On appeal to this court, the defendant
claims that the Superior Court exceeded its limited
scope of judicial review in making factual findings and
in substituting its judgment for that of the board, which,
the defendant maintains, properly affirmed the referee’s
denial of the plaintiff’s motion to open. We agree and,
accordingly, reverse the judgment of the Superior
Court.2
1
Caregiving by Kathy, the former employer of the plaintiff in the present
matter, and the Board of Review of the Employment Security Appeals Divi-
sion were named as additional defendants in the Superior Court; however,
neither of those parties is participating in this appeal. For ease of reference,
we refer in this opinion to the Administrator of the Unemployment Compen-
sation Act as the defendant.
2
Although the court’s remand order was interlocutory in nature, we deem
it to be a final judgment for purposes of appeal. ‘‘Under our existing case law,
we have distinguished . . . between two kinds of administrative remands.
A trial court may conclude that an administrative ruling was in error and
order further administrative proceedings on that very issue. In such circum-
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The following facts, as found by the referee and
adopted by the board, and procedural history are rele-
vant to our resolution of the defendant’s appeal. By way
of a decision mailed on January 12, 2021, the defendant
determined that the plaintiff was ineligible for unem-
ployment benefits, effective October 4, 2020 (January
12, 2021 decision).3 The notice of the January 12, 2021
decision mailed to the plaintiff provided that February
2, 2021, was the deadline by which the plaintiff could
file a timely appeal from the January 12, 2021 decision.
See General Statutes § 31-241 (a).4
stances, we have held the judicial order to be a final judgment, in order to
avoid the possibility that further administrative proceedings would simply
reinstate the administrative ruling, and thus would require a wasteful second
administrative appeal to the Superior Court on that very issue. . . . A trial
court may alternatively conclude that an administrative ruling is in some
fashion incomplete and therefore not ripe for final judicial adjudication.’’
(Internal quotation marks omitted.) Belica v. Administrator, Unemploy-
ment Compensation Act, 126 Conn. App. 779, 784 n.8, 12 A.3d 1067 (2011).
We conclude that ‘‘[t]he present case falls within the classification of adminis-
trative remands in which an administrative ruling was held to be in error
and further administrative proceedings are necessary on that very issue’’;
id.; such that the remand order constitutes an appealable final judgment.
3
The defendant further determined that the plaintiff had received $188
in unemployment benefits for which she was not eligible and that the plaintiff
did not qualify for a waiver for the overpayment.
4
General Statutes § 31-241 (a) provides in relevant part: ‘‘The decision of
the administrator shall be final . . . unless the claimant . . . within
twenty-one calendar days after such notification was provided to the claim-
ant . . . files an appeal from such decision and applies for a hearing, pro-
vided (1) any such appeal which is filed after such twenty-one-day period
may be considered to be timely filed if the filing party shows good cause,
as defined in regulations adopted pursuant to section 31-249h, for the late
filing, (2) if the last day for filing an appeal falls on any day when the offices
of the Employment Security Division are not open for business, such last
day shall be extended to the next business day, (3) if any such appeal is
filed by mail, such appeal shall be considered timely filed if it was received
within such twenty-one-day period or bears a legible United States postal
service postmark which indicates that within such twenty-one-day period
it was placed in the possession of such postal authorities for delivery to
the appropriate office, except posting dates attributable to private postage
meters shall not be considered in determining the timeliness of appeals filed
by mail, and (4) if any such appeal is filed electronically, such appeal shall
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On February 24, 2021, the plaintiff appealed to the
Employment Security Appeals Division (division) from
the January 12, 2021 decision. On April 6, 2021, the
division issued a notice that a telephonic hearing would
be held on April 14, 2021, limited to the issue of whether
the plaintiff had good cause for failing to file a timely
appeal. The plaintiff received the hearing notice in a
timely fashion and did not request a postponement;
however, she did not call in to the April 14, 2021 hearing
because she was at a hospital with her son, who had
been shot that same day. By way of a decision mailed
on April 16, 2021, the referee dismissed the plaintiff’s
appeal for lack of jurisdiction, determining that (1) the
appeal was untimely, (2) the plaintiff had failed to
appear at the April 14, 2021 hearing to pursue the appeal,
and (3) there was no evidence establishing good cause
for the untimely appeal (April 16, 2021 decision). The
April 16, 2021 decision further provided that May 7,
2021, was the deadline by which the plaintiff could file
a timely appeal therefrom. See General Statutes § 31-
248.5 The plaintiff received notice of the April 16, 2021
be considered timely filed if it was received within such twenty-one-day
period. . . .’’
5
General Statutes § 31-248 provides in relevant part: ‘‘(a) Any decision of
a referee, in the absence of a timely filed appeal from a party aggrieved
thereby or a timely filed motion to reopen, vacate, set aside or modify such
decision from a party aggrieved thereby, shall become final on the twenty-
second calendar day after the date on which a copy of the decision is
provided to the party, provided (1) any such appeal or motion which is filed
after such twenty-one-day period may be considered to be timely filed if
the filing party shows good cause, as defined in regulations adopted pursuant
to section 31-249h, for the late filing, (2) if the last day for filing an appeal
or motion falls on any day when the offices of the Employment Security
Division are not open for business, such last day shall be extended to the
next business day, (3) if any such appeal or motion is filed by mail, such
appeal or motion shall be considered to be timely filed if it was received
within such twenty-one-day period or bears a legible United States postal
service postmark which indicates that within such twenty-one-day period,
it was placed in the possession of such postal authorities for delivery to
the appropriate office, except posting dates attributable to private postage
meters shall not be considered in determining the timeliness of appeals or
motions filed by mail, and (4) if any such appeal is filed electronically, such
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decision in a timely fashion, and she also received other
written correspondence from the division in a timely
fashion and without incident.
From April through August, 2021, the plaintiff neither
called the division nor visited the division’s office. On
September 10, 2021, the plaintiff called the division to
ask for assistance. By that time, a separate claim that
the plaintiff had submitted seeking unemployment com-
pensation in connection with the COVID-19 pandemic
had been denied. On September 13, 2021, the plaintiff
filed a motion to open the April 16, 2021 decision
(motion to open). By way of a decision mailed on Sep-
tember 28, 2021, the referee conditionally granted the
motion to open, which the referee determined to be
late, and withdrew the April 16, 2021 decision provided
that the plaintiff demonstrated good cause for opening
the case. On October 22, 2021, the referee held a tele-
phonic hearing on the motion to open, which the plain-
tiff and a representative of her former employer
attended.
By way of a decision mailed on November 5, 2021,
the referee denied the motion to open and reinstated
the April 16, 2021 decision, reasoning that, although the
plaintiff may have demonstrated good cause for failing
appeal shall be considered timely filed if it was received within such twenty-
one-day period.
‘‘(b) Any decision of a referee may be reopened, set aside, vacated or
modified on the timely filed motion of a party aggrieved by such decision,
or on the referee’s own timely filed motion, on grounds of new evidence
or if the ends of justice so require upon good cause shown. The appeal
period shall run from the date a copy of the decision entered after any such
reopening, setting aside, vacation or modification, or a decision denying
such motion, as the case may be, was provided to the aggrieved party,
provided no such motion from any party may be accepted with regard to
a decision denying a preceding motion to reopen, vacate, set aside or modify
filed by the same party. An appeal to the board from a referee’s decision
may be processed by the referee as a motion for purposes of reopening,
vacating, setting aside or modifying such decision, solely in order to grant
the relief requested. . . .’’
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to attend the April 14, 2021 hearing on the basis of her
son’s shooting, she failed to establish good cause for
filing the motion to open more than eighteen weeks
late notwithstanding having received timely notice of
the April 16, 2021 decision. Additionally, the referee
determined that the plaintiff ‘‘did not pursue her appeal’’
in light of her failure to contact the division from April
through August, 2021, and that ‘‘she had a change of
heart after her application for [COVID-19] pandemic
unemployment assistance was denied.’’
On November 12, 2021, the plaintiff timely appealed
to the board from the referee’s denial of the motion to
open. See General Statutes § 31-249.6 By way of a deci-
sion mailed on June 20, 2022, the board affirmed the
denial of the motion to open and dismissed the plain-
tiff’s appeal. The board adopted the referee’s findings
of fact set forth in the April 16, 2021 decision, with the
exception of a scrivener’s error. The board determined
that (1) the plaintiff did not rebut the legal presumption
that she received timely notice of the April 16, 2021
decision, and (2) although ‘‘compelling personal cir-
cumstances,’’ including serious family emergencies,
preventing a party from filing a timely appeal or motion
may constitute good cause to permit a belated filing, it
‘‘must also consider a party’s diligence in filing the
appeal or motion once the reason for the late filing
no longer exists,’’ and the plaintiff did not exercise
diligence by waiting until September, 2021, to file the
motion to open. The board further noted that the plain-
tiff was requesting an evidentiary hearing and seeking to
supplement the record with certain medical documents.
The board declined these requests, determining that the
plaintiff did not demonstrate good cause to supplement
6
General Statutes § 31-249 provides in relevant part: ‘‘At any time before
the referee’s decision has become final within the periods of limitation
prescribed in section 31-248, any party including the administrator, may
appeal therefrom to the board. . . .’’
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the record when she could have submitted the proffered
medical documents to the referee during the hearing on
the motion to open. Additionally, the board determined
that, even if it were to consider the proffered medical
documents, they ‘‘would not excuse the [plaintiff’s]
lengthy delay in filing her motion to [open].’’
By way of a petition dated July 19, 2022, the plaintiff
timely appealed to the Superior Court from the board’s
decision.7 See General Statutes § 31-249b.8 The plaintiff
did not file a motion to correct the board’s findings
pursuant to Practice Book § 22-4.9 On February 5, 2024,
the defendant filed a brief on the merits contending that
the board’s decision was correct and that the plaintiff’s
administrative appeal should be dismissed.10
7
The petition contains a time stamp indicating that it was received by
the board on July 19, 2022; however, it was not filed with the Superior Court
until June 20, 2023. In its decision, the court, Cordani, J., noted that no
argument had been raised that the administrative appeal was untimely.
8
General Statutes § 31-249b provides in relevant part: ‘‘At any time before
the board’s decision has become final, any party, including the administrator,
may appeal such decision, including any claim that the decision violates
statutory or constitutional provisions, to the superior court for the judicial
district of Hartford or for the judicial district wherein the appellant resides.
. . .’’ See also General Statutes § 31-249a (a) (‘‘[a]ny decision of the board,
in the absence of a timely filed appeal from a party aggrieved thereby or a
timely filed motion to reopen, vacate, set aside or modify such decision
from a party aggrieved thereby, shall become final on the thirty-first calendar
day after the date on which a copy of the decision is provided to the party’’).
9
Practice Book § 22-4 provides: ‘‘If the appellant desires to have the finding
of the board corrected, he or she must, within two weeks after the record
has been filed in the Superior Court, unless the time is extended for cause
by the board, file with the board a motion for the correction of the finding
and with it such portions of the evidence as he or she deems relevant and
material to the corrections asked for, certified by the stenographer who
took it; but if the appellant claims that substantially all the evidence is
relevant and material to the corrections sought, he or she may file all of it,
so certified, indicating in the motion so far as possible the portion applicable
to each correction sought. The board shall forthwith upon the filing of the
motion and of the transcript of the evidence, give notice to the adverse
party or parties.’’
10
The plaintiff did not file a brief on the merits. In her petition, the plaintiff
stated that she ‘‘disagree[d] with the [board’s decision and] would like to
take this matter to court . . . .’’
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On April 22, 2024, the court, Cordani, J., heard argu-
ment on the petition. The plaintiff argued that she was
‘‘confused’’ by the unemployment compensation pro-
cess and ‘‘overwhelmed’’ by the paperwork that she
had received with respect thereto, stating that ‘‘I have
tons—for over three years, tons of paperwork. Tons of
back and forth, sending me here, sending me there . . .
constantly. . . . I could not apply for unemployment
[benefits] to get help when we were under the [COVID-
19] isolation. . . . [O]nce I applied for one thing, they
would put me on hold and tell me I would have to wait.’’
She further argued that there ‘‘wasn’t any lapse of time.
I had hardship. A lot of things went on. No, it’s no one’s
fault. Everybody [has] issues, but I had some serious
tragedy that went on in my life, and I still was trying
to stay grounded with what was going on. But every
single time, they just kept shooting me down, shooting
me down.’’ The defendant’s counsel conceded that the
COVID-19 pandemic had caused delays in proceedings
on unemployment claims; nevertheless, counsel main-
tained that the board’s decision was proper because
the plaintiff had failed to demonstrate good cause for
filing the motion to open late. Counsel further argued
that the court was bound by the factual findings made
by the referee and the board and that it could not rely
on evidence outside of the record to which the plaintiff
had alluded during her argument.
On April 23, 2024, the court issued its decision on
the plaintiff’s petition. The court stated that there was
no dispute that the motion to open was late; however,
the court concluded ‘‘that the agency did not reasonably
handle’’ its ‘‘determination of good cause and subse-
quent diligence.’’ The court determined that (1) the Jan-
uary 12, 2021 decision, which concerned a ‘‘remedial
basic benefit,’’ had not been subjected to a substantive
review, (2) ‘‘[t]he plaintiff’s application for unemploy-
ment benefits and the agency processes involving her
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application took place within the height of the [COVID-
19] pandemic at a time of turmoil and uncertainty for
the plaintiff and for the agency, [and] [e]ven the applica-
tion of agency procedures was uncertain during at least
portions of that time,’’ (3) on the day of the April 14,
2021 hearing, the plaintiff was at a hospital tending to
her son after he had been shot, and, ‘‘[a]s one might
expect, this incident had an effect on the plaintiff’s
ability to deal with her agency litigation beyond the
day of the shooting, placing physical, mental, and time
restraints upon the plaintiff for some time thereafter,’’
(4) ‘‘[t]he plaintiff convincingly argued to the court that
she was confused by the agency and the many letters
and communications she received from [it], [and she]
also convincingly argued that the agency misled her,’’
with additional ‘‘confusion [being] created by the
agency in that the agency directed the plaintiff to multi-
ple programs,’’ and (5) the board refused to consider
the medical documents proffered to it by the plaintiff,
which documents ‘‘apparently [were] not even entered
into the record.’’ The court continued: ‘‘In view of the
foregoing, the court hereby remands this matter back
to the . . . referee to reconsider the agency’s determi-
nation concerning good cause and diligence in light of
the foregoing factors and in further view of the medical
evidence proffered by the plaintiff.’’ This appeal fol-
lowed. Additional facts and procedural history will be
set forth as necessary.

The defendant claims that the court exceeded its
limited scope of judicial review in making factual find-
ings and substituting its judgment for that of the board,
which, the defendant contends, properly affirmed the
referee’s denial of the motion to open. The plaintiff
argues that the court properly exercised its discretion
to conclude that the board acted unreasonably in
determining that she failed to establish good cause for
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her belated filing of the motion to open. We agree with
the defendant.11
‘‘The standard of review for judicial review of this
type of case is well established. In appeals under . . .
§ 31-249b, the Superior Court does not retry the facts
or hear evidence but rather sits as an appellate court
to review only the record certified and filed by the
board . . . . The court is bound by the findings of sub-
ordinate facts and reasonable factual conclusions made
by the . . . referee where, as here, the board . . .
adopted the findings and affirmed the decision of the
referee. . . . Judicial review of the conclusions of law
reached administratively is also limited. The court’s
ultimate duty is only to decide whether, in light of the
evidence, the board . . . has acted unreasonably, arbi-
trarily, illegally, or in abuse of its discretion.’’ (Internal
quotation marks omitted.) Mendes v. Administrator,
Unemployment Compensation Act, 199 Conn. App. 25,
30, 235 A.3d 665 (2020); see also Blossom’s Escort, LLC
v. Administrator, Unemployment Compensation Act,
184 Conn. App. 448, 454, 195 A.3d 417 (2018)
(‘‘[a]lthough the court may not substitute its own con-
clusions for those of the administrative board, it retains
the ultimate obligation to determine whether the admin-
istrative action was unreasonable, arbitrary, illegal or
11
Embedded within the defendant’s claims is an apparent separate asser-
tion that the court improperly determined that the board refused to consider
the medical documents proffered to it by the plaintiff. Insofar as this is a
distinct claim of error, we agree with the defendant. In rejecting the plaintiff’s
requests for an evidentiary hearing and to supplement the record with the
proffered medical documents, the board determined that (1) the plaintiff
could have presented the documents to the referee during the hearing on
the motion to open, such that there was no ‘‘good cause to supplement the
record at this late stage in the proceedings,’’ and (2) even if it were to
consider the documents, they ‘‘would not excuse the [plaintiff’s] lengthy
delay in filing her motion to [open].’’ Thus, we disagree with the court’s
characterization that the board refused to consider the proffered medical
documents; rather, the board determined that there was no good cause
shown to permit their belated submission, and, in any event, they would
not establish good cause for the late filing of the motion to open.
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an abuse of discretion’’ (internal quotation marks omit-
ted)).
‘‘In an appeal to the court from a decision of the
board, the court is not to find facts. . . . In the absence
of a motion to correct the finding of the board [pursuant
to Practice Book § 22-4], the court is bound by the
board’s finding.’’ (Citations omitted.) Ray v. Adminis-
trator, Unemployment Compensation Act, 133 Conn.
App. 527, 533, 36 A.3d 269 (2012); see also Mendes
v. Administrator, Unemployment Compensation Act,
supra, 199 Conn. App. 30 (‘‘[a] plaintiff’s failure to file
a timely motion for correction of the board’s findings
in accordance with . . . § 22-4 prevents further review
of those facts found by the board’’ (internal quotation
marks omitted)).
In denying the motion to open, the referee made
factual findings, which were adopted by the board,
including that (1) the plaintiff did not participate in the
April 14, 2021 hearing because she was at a hospital
with her son after he had been shot, (2) the plaintiff
received notice of the ensuing April 16, 2021 decision
in a timely manner, (3) the plaintiff did not contact
the division between April and August, 2021, (4) on
September 10, 2021, the plaintiff contacted the division
for help after a separate application that she had filed
for unemployment benefits attendant to the COVID-19
pandemic had been denied, and (5) on September 13,
2021, the plaintiff filed the motion to open, which was
more than eighteen weeks late. We further discern the
board to have found that the family emergency involving
the plaintiff’s son that occurred on April 14, 2021, did
not prevent the plaintiff from filing the motion to open
in a timely manner, as the board observed that it ‘‘must
also consider a party’s diligence in filing the appeal or
motion once the reason for the late filing no longer
exists’’ and found that the plaintiff ‘‘waited’’ until Sep-
tember, 2021, to file the motion to open. The plaintiff
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did not file a motion to correct pursuant to Practice
Book § 22-4, such that the court ‘‘was bound by the
[aforementioned] factual findings and was called on
to assess only whether the board’s ultimate finding,
namely, whether the plaintiff had failed to establish
good cause, was reasonable and logical in light of the
factual findings.’’ Mendes v. Administrator, Unemploy-
ment Compensation Act, supra, 199 Conn. App. 36.
Nevertheless, in adjudicating the plaintiff’s adminis-
trative appeal, the court found facts beyond those con-
tained in the certified record, including findings predi-
cated in part on representations made by the plaintiff
during the April 22, 2024 hearing. Notably, the court
made findings with regard to the effects of (1) the
COVID-19 pandemic on unemployment compensation
proceedings, (2) the shooting of the plaintiff’s son ‘‘on
the plaintiff’s ability to deal with her agency litigation
beyond the day of the shooting,’’ and (3) agency commu-
nications received by the plaintiff, upon which findings
the court relied to conclude that the board’s decision
was not reasonable. Put simply, the court exceeded its
limited scope of judicial review by engaging in such
fact-finding and by relying on its improper findings in
examining the board’s decision. See Seward v. Admin-
istrator, Unemployment Compensation Act, 191 Conn.
App. 578, 586, 215 A.3d 202 (2019) (Superior Court
‘‘exceeded the scope of [court’s] review’’ by finding
facts, which formed basis of court’s determination that
board abused its discretion); Chicatell v. Administra-
tor, Unemployment Compensation Act, 145 Conn. App.
143, 151–52, 74 A.3d 519 (2013) (Superior Court
‘‘exceeded [its] limited scope of review’’ by, in essence,
finding facts and substituting them for those of referee
and board when it relied on ‘‘ ‘uncontradicted testi-
mony’ ’’ in form of assertions made by plaintiff on
appeal forms to board and to court); Ray v. Administra-
tor, Unemployment Compensation Act, supra, 133
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Conn. App. 534 (Superior Court ‘‘erred by accepting as
true facts that the board did not find and by basing
its conclusions on those facts’’).12 On the basis of the
controlling factual findings set forth in the certified
record, we cannot conclude that the board acted unrea-
sonably, arbitrarily, illegally, or in abuse of its discretion
in affirming the referee’s denial of the motion to open.
The judgment is reversed and the case is remanded
with direction to render judgment affirming the decision
of the Board of Review of the Employment Security
Appeals Division.
In this opinion the other judges concurred.

12
The plaintiff relies on Burnham v. Administrator, Unemployment Com-
pensation Act, 184 Conn. 317, 439 A.2d 1008 (1981), for the proposition that
the court properly ‘‘exercised its discretion when entertaining questions
that might have been, but were not, raised before the referee or the board
when reviewing the plaintiff’s [administrative] appeal, and considering her
lack of experience and status as a pro se litigant.’’ This reliance is misplaced.
In Burnham, our Supreme Court stated that the ‘‘well-recognized limitations
on judicial review [in administrative appeals brought pursuant to § 31-249b]
do not require courts to abstain entirely from entertaining questions that
might have been, but were not, raised before the administrative tribunal.
Reviewing courts retain considerable latitude, in ordinary legal proceedings,
to consider matters not raised in the trial court. . . . The standard for review
of administrative proceedings similarly must allow for judicial scrutiny of
claims such as constitutional error . . . jurisdictional error . . . or error
in the construction of the administrative agency’s authorizing statute. . . .
In addition, the leniency traditionally afforded to inexperienced pro se par-
ties may justify belated consideration of claims not fully explored in earlier
proceedings.’’ (Citations omitted.) Id., 322–23. In her administrative appeal,
the plaintiff did not raise claims of constitutional error, jurisdictional error,
or error in the construction of an authorizing statute. Moreover, we do not
construe Burnham as endorsing improper fact-finding by the Superior Court
when the plaintiff is a self-represented party. See, e.g., Belica v. Administra-
tor, Unemployment Compensation Act, 126 Conn. App. 779, 787, 12 A.3d
1067 (2011) (notwithstanding policy of courts to be solicitous of rights of
self-represented parties, Superior Court lacked authority to consider self-
represented plaintiff’s challenge of board’s findings when plaintiff failed to
file motion to correct pursuant to Practice Book § 22-4).
Additionally, the plaintiff argues that we should not review a portion of
the defendant’s claims on appeal because the record is inadequate for review
and the defendant failed to file a motion for articulation pursuant to Practice
Book § 66-5. In short, we conclude that the record is adequate for our review.