Amelio v. Amelio
CourtConnecticut Appellate Court
Date FiledSeptember 22, 2026
DocketAC48133
JudgeMoll; Suarez; Westbrook
StatusPublished
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Full Opinion
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Amelio v. Amelio
ANASTASIA R. AMELIO v. CARMINE P. AMELIO
(AC 48133)
Moll, Suarez and Westbrook, Js.
Syllabus
The defendant, whose marriage to the plaintiff had previously been dis-
solved, appealed from the trial court’s judgments granting two motions for
contempt filed by the plaintiff. The defendant claimed, inter alia, that the
court improperly held him in contempt for violating the parties’ separation
agreement by failing to pay the plaintiff $300 per month for their children’s
expenses. Held:
This court declined to review the defendant’s claims on appeal, as they were
inadequately briefed.
Argued April 28—officially released September 22, 2026
Procedural History
Action for the dissolution of a marriage, and for other
relief, brought to the Superior Court in the judicial
district of Danbury and tried to the court, Winslow, J.;
judgment dissolving the marriage and granting certain
other relief in accordance with the parties’ separation
agreement; thereafter, the court, Laskos, J., granted
the plaintiff’s motion for contempt, and the defendant
appealed to this court; subsequently, the court, Vizcar-
rondo, J., granted the plaintiff’s motion for contempt,
and the defendant filed an amended appeal. Affirmed.
Carmine P. Amelio, self-represented, the appellant
(defendant).
Anastasia R. Amelio, self-represented, the appellee
(plaintiff).
Opinion
SUAREZ, J. The self-represented defendant, Carmine
P. Amelio, appeals from the judgments of the trial court
granting two postjudgment motions for contempt filed
by the self-represented plaintiff, Anastasia R. Amelio.
On appeal, the defendant raises a multitude of claims
regarding the court’s decisions to find him in contempt
for (1) violating the parties’ separation agreement by
Amelio v. Amelio
failing to pay the plaintiff $300 per month for their
children’s expenses and (2) violating the parties’ joint
custody arrangement as to the driving rights of the par-
ties’ seventeen and one-half year old son. We affirm the
judgments of the trial court.
The following facts and procedural history are rel-
evant to this appeal. The parties were married on July
4, 2004, and have two issue of the marriage. Following
the subsequent breakdown of the parties’ marriage, the
parties entered into a separation agreement that the
court, Winslow, J., incorporated into its judgment of
dissolution. The court found that the parties’ marriage
had broken down irretrievably, found that the parties’
separation agreement was fair and equitable, and, on
June 26, 2013, rendered judgment dissolving the par-
ties’ marriage.
Pursuant to the separation agreement, the parties
agreed that “[m]ajor decisions, which shall be defined
as those key issues affecting each child’s health, growth
and development; course of study; extent of travel away
from home, including participation on sports travel
team(s); choice of camp; major medical treatment; les-
sons; psychotherapy, psychoanalysis or like treatment;
part or full-time employment; purchase or operation of
a motor vehicle; [e]specially hazardous sports or activi-
ties; religious upbringing; non-emergency health care;
significant changes in social environment; and decisions
relating to actual or potential litigation involving a child
directly or as a beneficiary, other than custody, shall be
considered in depth and agreed to between the parties.
Neither party shall make any major decisions regarding
either minor child without the other party’s express con-
sent or pursuant to further [c]ourt order. The [parties]
specifically recognize that the privileges conferred by a
joint custody arrangement shall not be exercised for the
purpose of frustrating, denying or controlling, in any
manner, the lifestyle of the other [party].”
The parties further agreed that “[d]ay-to-day deci-
sions of a routine nature, including but not limited to
Amelio v. Amelio
bedtime, homework, health care, and day-to-day school,
religious, social and athletic activities customary for a
child of his or her age and maturity, and general rules
of conduct, such as prohibited activities, curfews, and
household obligations, shall be made by the [party] with
whom the children are actually then staying. The [parties]
shall cooperate and establish a mutually agreeable policy
regarding such day-to-day decisions, but the primary
responsibility for routine decisions shall rest with the
[party] with whom the children are then staying.”
Moreover, the parties agreed that “no child support
shall be payable from one party to the other” but that
the defendant was obligated to “pay to the [plaintiff]
the sum of [$300] per month as his contribution towards
clothing, grooming expenses, school related expenses
including lunches, birthday parties and school trips,
summer camps, etc. incurred on behalf of the minor
children. Notwithstanding the foregoing, nothing in
this paragraph shall create a right in the [defendant] to
seek reimbursement for any such items he purchases on
behalf of the children.”
On November 17, 2023, the plaintiff filed a postjudg-
ment motion for contempt (November 2023 contempt
motion). The plaintiff alleged therein that the defen-
dant had “not paid his ‘kid expense payments’ of $300
per month . . . for September 2023, October 2023, and
November 2023 for a total amount owed of $900.” The
court ordered the parties to appear for a resolution
plan date1 on December 15, 2023. Over the next several
months, the court granted several continuances of that
date.
In April 2024, the defendant filed a request for a con-
tinuance and, alternatively, requested a “remote hearing
1
See Practice Book § 25-50A (“[t]he Pathways approach shall be fol-
lowed and shall include: (a) [a] resolution plan date, which shall be
assigned in dissolution of marriage . . . cases . . . to meet with a family
relations counselor to identify: (1) all matters where the parties agree;
(2) how likely the parties are to reach an agreement on any disputed
issues; and (3) the resources needed to resolve the case”).
Amelio v. Amelio
pursuant [to his] request [pursuant to the Americans with
Disabilities Act, 42 U.S.C. § 12101 et seq., and] medical
issues.” The court denied the continuance but granted
the defendant’s request to appear remotely. Also in April
2024, the defendant filed a motion for modification seek-
ing to eliminate his monthly $300 contribution nunc
pro tunc effective August 2023. The court scheduled
a resolution plan date on the defendant’s motion for
modification for May 24, 2024, but the defendant filed
a request for a continuance, which the court granted.
The court held a hearing on the November 2023 con-
tempt motion on June 25, 2024. At the hearing, the
defendant requested that the court state its oath of
office to ensure that he “can have that confidence that
we’re gonna have a fair and impartial hearing.” The
court denied the request. The defendant then orally
requested another continuance so that the court could
rule on his motion for modification. The court also denied
that request.
The plaintiff testified at the June 25, 2024 hearing
that the defendant made a partial payment of his owed
monthly contributions in January 2024, which covered
his monthly payment obligations through November
2023. The plaintiff then testified that, since that time,
the defendant had failed to pay any of his contribution
amounts owed and that he was seven months in arrears
on his payments. The defendant testified that he did not
“have the ability to pay . . . .” At the conclusion of the
hearing, the court kept the evidence open and ordered
the defendant to file a financial affidavit.
On August 1, 2024, the plaintiff filed another post-
judgment motion for contempt (August 2024 contempt
motion), alleging that the defendant violated the disso-
lution judgment by, inter alia, withholding their son’s
driver’s license, thereby limiting their son’s ability to
drive while he was in the plaintiff’s physical custody.
On September 3, 2024, the court granted the November
2023 contempt motion. The court found the plaintiff’s
Amelio v. Amelio
testimony to be credible and did not credit the defen-
dant’s testimony that he could not pay the plaintiff.
The court ordered the defendant to pay the plaintiff
$2100 by October 4, 2024, representing the payments
owed between December 2023 and July 2024, with inter-
est accruing at the rate of 8 percent per annum. The
defendant filed a motion for clarification and a motion
to reargue/reconsider, both of which the court denied.
Thereafter, the defendant timely appealed to this court.
On December 19, 2024, the court, Vizcarrondo, J.,
held a hearing on the August 2024 contempt motion.
At the hearing, the defendant again requested that the
court state its oath of office “[f]or the purposes of impar-
tiality and clarity . . . .” The court denied the request.
During the hearing, the defendant iterated his request
to continue the hearing on the August 2024 contempt
motion until there was a ruling on his motion for modi-
fication. The court denied that request, stating that the
defendant’s motion for modification “has nothing to do
with historically what we’re [talking] about here. If [the
motion for modification is] granted, it will be granted
going forward.” The court further stated: “[The plain-
tiff] has the right to file a contempt action, sir. She has
the right. You have an agreement. She believes it’s not
being complied with . . . .”
After hearing from both parties, the court granted the
August 2024 contempt motion, finding that the defen-
dant “violated the parties’ joint custody arrangement”
and that he “has imposed, unilaterally, a list of significant
prohibitions on [the ability of the parties’ son] to drive
a motor vehicle.” The court noted that “[t]he defendant
testified stridently that he has every right as a father
to impose restrictions on his minor child, regardless of
whether the state of Connecticut has granted [the parties’
son] an unrestricted driver’s license, which it has. . . .
For her part, the plaintiff agreed that as a recently
licensed driver, certain limitations on [the ability of
the parties’ son] to drive are reasonable, but she objects
Amelio v. Amelio
to the universal imposition of such restrictions during
her parenting time without her input and consent.”
The court determined that the parties’ separation
agreement clearly and unambiguously required that
the parties mutually agree on whether their son could
operate a motor vehicle during his minority. The court
stated that the parties “agreed that he should, [and] he
therefore obtained a license . . . .” The court determined
that, because the parties’ son was a “duly licensed driver
under Connecticut law,” his operation of a motor vehicle
was “relegated to an ongoing ‘day-to-day decision of a
routine nature’ ” and stated that the parties’ agreement
“expressly provides that each has authority to establish
‘general rules of conduct,’ to include ‘prohibited activi-
ties’ for their son’s protection.”
The court concluded that, “[i]n dictating the terms
and conditions under which [the parties’ son] may drive,
including during the plaintiff’s parenting time, the
defendant has acted wilfully to suppress the plaintiff’s
parenting authority in violation of the joint custody
arrangement. He is adjudicated in contempt by clear
and convincing evidence.” The court further concluded
that, even if the driving privileges of the parties’ son
remained a “major decision subject to mutual consent,
the defendant has wilfully violated the agreement’s good
faith provision.” The court found that, in contravention
of their joint custody arrangement, “[i]n this case, the
defendant has made clear that it is his way or the high-
way. . . . [T]his court finds that the defendant is wilfully
and unreasonably . . . ‘frustrating and controlling the
lifestyle of the other parent.’ For that independent rea-
son, the court finds, by clear and convincing evidence,
that the defendant is in wilful contempt of the joint
parenting arrangement.” The defendant subsequently
filed an amended appeal to include the court’s granting
of the August 2024 contempt motion.
We begin by setting forth the following legal prin-
ciples. “[T]he court’s authority to impose civil contempt
penalties arises not from statutory provisions but from
Amelio v. Amelio
the common law. . . . The penalties which may be imposed
. . . arise from the inherent power of the court to coerce
compliance with its orders. In Connecticut, the court
has the authority in civil contempt to impose on the
contemnor either incarceration or a fine or both.” (Inter-
nal quotation marks omitted.) Jacob-Dick v. Dick, 231
Conn. App. 404, 415, 333 A.3d 210 (2025). “To consti-
tute 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 contemnor’s wilful noncompliance with that
directive. . . . [T]he trial court’s determination that the
violation was wilful [is governed by] the abuse of discre-
tion standard. . . . We review the factual findings that
underlie a court’s contempt determination pursuant
to the clearly erroneous standard.” (Citations omitted;
internal quotation marks omitted.) Id., 411–12. We now
turn to the issues raised on appeal.
I
The defendant first claims that the court improperly
granted the plaintiff’s November 2023 contempt motion.
Specifically, the defendant argues that the court (1)
improperly failed to conduct an ability to pay hearing
with a jury in violation of his rights pursuant to the
seventh amendment to the United States constitution;
(2) violated his due process rights by intentionally delay-
ing and refusing to hear his motion for modification; (3)
fraudulently mischaracterized a voluntary $300 monthly
payment as child support; (4) violated the Americans with
Disabilities Act by denying his requests for reasonable
accommodations; and (5) “fail[ed] to provide adequate
findings and conclusions and [engaged in] dismissive and
disparaging conduct towards [the defendant] [in viola-
tion of] principles of fairness and impartiality.” Having
thoroughly reviewed the record and the defendant’s
appellate briefs, we conclude that we cannot properly
Amelio v. Amelio
address this claim on appeal because it is inadequately
briefed, and, thus, we decline to review it.
“We repeatedly have stated that [w]e are not required
to review issues that have been improperly presented
to this court through an inadequate brief. . . . Analy-
sis, 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. . .
. For a reviewing court to judiciously and efficiently . . .
consider claims of error raised on appeal . . . the parties
must clearly and fully set forth their arguments in their
briefs. . . . In addition, briefing is inadequate when it is
not only short, but confusing, repetitive, and disorga-
nized.” (Internal quotation marks omitted.) Alterio v.
Spak, 237 Conn. App. 84, 90, 349 A.3d 614 (2026).
Moreover, “[t]he parties may not merely cite a legal
principle without analyzing the relationship between the
facts of the case and the law cited. . . . [A]ssignments of
error which are merely mentioned but not briefed beyond
a statement of the claim will be deemed abandoned and
will not be reviewed by this court.” (Internal quotation
marks omitted.) Russell v. Russell, 91 Conn. App. 619,
635, 882 A.2d 98, cert. denied, 276 Conn. 924, 888 A.2d
92 (2005), and cert. denied, 276 Conn. 925, 888 A.2d
92 (2005).
“We are mindful that [i]t is the established policy of the
Connecticut courts to be solicitous of [self-represented]
litigants and when it does not interfere with the rights
of other parties to construe the rules of practice liberally
in favor of the [self-represented] party. . . . Nonetheless,
[a]lthough we allow [self-represented] litigants some
latitude, the right of self-representation provides no
attendant license not to comply with relevant rules of
procedural and substantive law.” (Internal quotation
marks omitted.) Thomas v. Cleary, 229 Conn. App. 15,
36, 326 A.3d 1109 (2024).
Amelio v. Amelio
In the present case, the defendant first argues that, in
granting the November 2023 contempt motion, the court
improperly failed to conduct a jury trial on his ability to
pay in violation of his seventh amendment rights. The
defendant devotes less than one page of analysis to this
claim in his principal appellate brief. “Although the
number of pages devoted to an argument in a brief is
not necessarily determinative, relative sparsity weighs
in favor of concluding that the argument has been inad-
equately briefed.” State v. Buhl, 321 Conn. 688, 726,
138 A.3d 868 (2016). This is especially so with respect
to constitutional claims, “which are often analytically
complex.” Id.; see also Estate of Rock v. University of
Connecticut, 323 Conn. 26, 33, 144 A.3d 420 (2016)
(“[c]laims are . . . inadequately briefed when they . . .
consist of conclusory assertions . . . with no mention of
relevant authority and minimal or no citations from the
record” (internal quotation marks omitted)).
The defendant cites to two federal decisions in support
of his seventh amendment claim: Turner v. Rogers, 564
U.S. 431, 131 S. Ct. 2507, 180 L. Ed. 2d 452 (2011),
and Jarkesy v. Securities & Exchange Commission,
34 F.4th 446 (5th Cir. 2022), aff’d, 603 U.S. 109, 144
S. Ct. 2117, 219 L. Ed. 2d 650 (2024). The defendant,
however, did not engage in any meaningful analysis of
how those authorities apply to the present case.2 “[F]or
this court judiciously and efficiently to consider claims
of error raised on appeal . . . the parties must clearly and
fully set forth their arguments in their briefs. . . . The
2
The limited arguments presented by the defendant in support of this
claim are difficult to understand, conclusory, and/or incorrect. See,
e.g., Matusz v. Wellmore Behavioral Health, Inc., 234 Conn. App.
581, 593–94, 344 A.3d 208, cert. denied, 353 Conn. 926, 345 A.3d
811 (2025) (“[i]t is not enough merely to mention a possible argument
in the most skeletal way, leaving the court to do counsel’s work, create
the ossature for the argument, and put flesh on its bones” (internal
quotation marks omitted)). The defendant baldly asserts that “[t]he
contempt sanctions imposed without an ability to pay hearing or jury
trial contravene [Jarkesy v. Securities & Exchange Commission, supra,
34 F.4th 446], which mandates jury trials for punitive civil contempt.”
The defendant’s reliance on Jarkesy, however, is misplaced, as that
case concerned the issue of whether the right to a jury trial applied to
Amelio v. Amelio
parties may not merely cite a legal principle without
analyzing the relationship between the facts of the case
and the law cited.” (Internal quotation marks omitted.)
Hadji v. Snow, 232 Conn. App. 829, 858, 339 A.3d
1168, cert. denied, 353 Conn. 902, 341 A.3d 958 (2025).
Similarly, the defendant refers to certain guidelines
from the United States Department of Justice that he
alleges the court violated, without explaining what those
guidelines specifically provide and without engaging
in any meaningful analysis of how the court allegedly
violated those guidelines.3
Likewise, the defendant’s briefing of his argument
that the court violated his due process rights by delay-
ing and/or refusing to hear his motion for modification
is wholly deficient. The defendant asserts that the court
intentionally delayed and/or refused “to hear [his] timely
motion for modification,” but he does not provide any
legal authority or analysis to support his claim on appeal.
The defendant has not offered any reason as to why the
court could not have ruled on the plaintiff’s motion for
contempt, particularly as the record reveals that the
defendant himself requested a continuance of the hearing
on his motion for modification, which the court granted.
As this court has previously stated, “[i]t was incumbent
on the [defendant] to provide a meaningful analysis of
his claim[s] . . . and to include citations to relevant legal
authority and an application of that law to the facts in
the present case. . . . [I]t is not enough merely to mention
a possible argument in the most skeletal way, leaving
the court to do counsel’s work, create the ossature for
actions brought by the Securities and Exchange Commission seeking
civil penalties under securities statutes. Id., 453–54.
In even more cursory fashion, the defendant cites to Turner v. Rogers,
supra, 564 U.S. 431, without offering any analysis concerning that case
at all. In any event, Turner did not address the right to a jury trial at
all and is thus inapposite to the defendant’s claim.
3
Although the defendant asserts that the Department of Justice guide-
lines “prohibit incarceration absent [a] wilfulness determination,” he
does not claim that he was wrongfully incarcerated by the court, and,
furthermore, the court in the present case did find that the defendant
wilfully failed to pay the plaintiff the ordered amounts.
Amelio v. Amelio
the argument, and put flesh on its bones.” (Citations
omitted; emphasis omitted; internal quotation marks
omitted.) Matusz v. Wellmore Behavioral Health, Inc.,
234 Conn. App. 581, 593–94, 344 A.3d 208, cert. denied,
353 Conn. 926, 345 A.3d 811 (2025).
With respect to the defendant’s claim that the court
“fraudulently mischaracterize[d] a voluntary $300
monthly payment as child support to obtain Title IV-D
funding,” he has failed to cite to any such mischarac-
terization in the record. Finally, the defendant has not
cited to any applicable legal authorities or conducted
any analysis in support of his argument. See, e.g., C. B.
v. S. B., 211 Conn. App. 628, 631, 273 A.3d 271 (2022)
(brief containing minimal relevant citation to record or
applicable legal authorities was inadequately briefed).
We therefore decline to review it.
Next, the defendant argues that the court improperly
denied him reasonable accommodations under the Ameri-
cans with Disabilities Act, “despite documented history
and limitations . . . .” Apart from his bare assertion that
he had a “documented medical history,” however, the
defendant does not identify any specific accommoda-
tion request that was denied to him by the court, much
less provide an explanation as to why such a request was
denied improperly. To the contrary, the record reveals
that the court did grant the defendant’s request for a
remote hearing in light of his request under the Ameri-
cans with Disabilities Act. Because it is unclear exactly
which of the court’s rulings the defendant is challenging,
we are unable to review his claim.
Lastly, the defendant’s claim that the court violated the
principles of fairness and impartiality by failing to pro-
vide adequate findings and conclusions and in its “dismis-
sive and disparaging conduct towards [the defendant]” is
similarly deficient. In support of his claim, the defendant
asserts that the court “[e]xhibit[ed] clear judicial bias
through improper conduct.” The only specific conduct
mentioned in his brief, however, is the court’s refusal to
restate its judicial oath and its “[d]isparagement of [the
Amelio v. Amelio
defendant] for attending a family burial and denial of
[Americans with Disabilities Act] accommodations . . . .”4
The defendant fails to provide any citation supporting
his proposition that the court was obligated to restate its
judicial oath upon his request, and he does not provide
any legal analysis as to his claim on appeal. Accordingly,
“the sparsity and lack of substantive argument cause [his]
brief to be inadequate for us to conduct any meaningful
review of this claim.” (Internal quotation marks omitted.)
Thomas v. Cleary, supra, 229 Conn. App. 37. For the
foregoing reasons, we decline to review the defendant’s
first claim as it is inadequately briefed.
II
The defendant’s second claim is that the court improp-
erly granted the August 2024 contempt motion. Specifi-
cally, the defendant argues5 that the court (1) violated his
fundamental right to direct his minor child’s upbring-
ing; (2) improperly denied his motion for a continuance
and improperly refused to restate its judicial oath; (3)
should have been disqualified from presiding over the
proceedings; (4) improperly ignored his parental rights
over his son’s driving privileges pursuant to statute;
(5) violated his due process rights; (6) exhibited bias
and improperly refused to follow its own calendar; (7)
improperly overrode his fundamental parental rights
in violation of his constitutional rights; (8) improperly
excluded critical evidence concerning child safety; and
(9) exhibited judicial bias and denied the defendant a fair
hearing due to procedural irregularities. We conclude
that this claim, too, is inadequately briefed, and we
therefore decline to address it.
The defendant first argues that the court, in denying the
August 2024 contempt motion, violated his fundamental
4
Our review of the record does not reveal any disparaging statements
made by the trial court toward the defendant for attending a funeral,
nor does the defendant cite to any specific statements made by the court
concerning this issue.
5
For the purpose of clarity, we address these arguments in a slightly
different order than they are set forth in the defendant’s principal
appellate brief.
Amelio v. Amelio
right to direct his minor child’s upbringing.6Apart from
his bald assertion that the court violated his rights, how-
ever, the defendant has not engaged in any meaningful
analysis of this claim and why the court’s decision was
erroneous. The defendant cites to Troxel v. Granville,
530 U.S. 57, 60, 120 S. Ct. 2054, 147 L. Ed. 2d 49 (2000),
but does not provide any analysis of how that case applies
to the present one.7
The defendant also asserts, in conclusory fashion, that
the court improperly denied his motion for a continuance
with regard to the hearing on the August 2024 contempt
motion in violation of his due process rights.8 The defen-
dant’s briefing to this court, however, does not address
the basis for the court’s denial of his motion for a continu-
ance. Although the defendant argued that his motion for
modification should be ruled on before the court’s hearing
on the August 2024 contempt motion, the court rejected
this assertion, stating that the defendant’s motion for
6
The defendant similarly asserts that the court’s “findings of con-
tempt for a parenting disagreement violated due process” and that the
court improperly “over[rode] [the defendant’s] fundamental parental
rights without mutual consent, violating constitutional protections.”
(Emphasis omitted.) We conclude that these arguments, which con-
sist of less than one page each of analysis, are merely repetitive of
his assertion that his fundamental rights to direct his minor child’s
upbringing were violated and are also inadequately briefed. See C. B.
v. S. B., supra, 211 Conn. App. 630 (“briefing is inadequate when it is
not only short, but confusing, repetitive, and disorganized” (internal
quotation marks omitted)).
7
Even if this claim had been adequately briefed, we note that the
court’s ruling on the driving privileges of the parties’ minor son merely
reflected its interpretation of the parties’ separation agreement. Fur-
thermore, this court previously has stated with respect to a parent’s
constitutional right to make reasoned decisions about the welfare of
their minor children that cases such as Troxel v. Granville, supra, 530
U.S. 57, “shed no light on custody disputes between parents because
each parent has an equal and undiminished constitutional right to make
reasoned decisions about the welfare of his or her minor children.”
(Emphasis omitted.) Kennedy v. Kennedy, 114 Conn. App. 143, 153
n.8, 968 A.2d 1002, cert. denied, 292 Conn. 918, 973 A.2d 1275 (2009).
8
In support of his second claim, the defendant again argues that the
court improperly refused to restate its judicial oath. In part I of this
opinion, we have rejected the defendant’s contention, and we need not
revisit that issue here.
Amelio v. Amelio
modification “has nothing to do with historically what
we’re [talking] about here. If [the motion for modifica-
tion is] granted, it will be granted going forward.” The
court further stated: “[The plaintiff] has the right to
file a contempt action, sir. She has the right. You have
an agreement. She believes it’s not being complied with
. . . .” Thus, by failing to address the dispositive bases
for the court’s denial of the defendant’s request for a
continuance, his brief is inadequate for us to conduct any
meaningful review of this claim.9 See, e.g., Sicignano v.
Pearce, 228 Conn. App. 664, 692, 325 A.3d 1127 (2024)
(concluding that, by failing to address dispositive bases
for court’s conclusions, plaintiff’s brief was inadequate),
cert. denied, 351 Conn. 908, 330 A.3d 881 (2025). Apart
from labeling the court’s ruling denying his request for
a continuance as “misconduct,” he has not provided any
analysis of this argument, and, therefore, we decline to
review it.
Likewise, the defendant argues that the court improp-
erly ignored his parental rights over his son’s driving
privileges pursuant to statute, but he has not provided
any analysis of this claim. The defendant relies on Gen-
eral Statutes § 14-36 (c), but that statutory provision
concerns the right of a person who is sixteen or seventeen
years of age to obtain a youth instruction permit.10 The
defendant also asserts that the court did not apply what
he refers to as “safety factors” that this court allegedly
applied in In re Tayquon H., 76 Conn. App. 693, 821
A.2d 796 (2003), but, upon our review, that decision
9
Although the defendant asserts that the proceedings on the August
2024 contempt motion were “[r]ushed” and that he had inadequate
time to prepare a defense, again, the defendant has not pointed to any
specific exhibits that he was not able to access before the hearing, and
he has not pointed to any arguments that he purportedly required more
time to prepare to articulate to the court.
10
At the December 19, 2024 hearing before the court, the defendant
did not dispute that he allowed the parties’ minor son to obtain a youth
instruction permit. The defendant stated: “[The plaintiff] stated that I
purposely held back his permit. She’s stating that I wouldn’t allow [the
parties’ minor child] to drive. Those are all lies, Your Honor.”
Amelio v. Amelio
does not refer to any such “factors”11 and, moreover,
that case concerned whether a maternal grandmother
had standing to contest an order of temporary custody
involving her grandchild.
The defendant makes several arguments in support of
his second claim concerning judicial bias and/or miscon-
duct, all of which are inadequately briefed. Specifically,
the defendant asserts that the court, Vizcarrondo, J.,
should have been disqualified from presiding over the
contempt hearings in the present case because of his
“prior removal by marshals . . . .” The sole support offered
by the defendant with respect to this argument is his
attachment to his principal appellate brief of an article
purportedly discussing Judge Vizcarrondo, which the
defendant had attached as an exhibit to a June 13, 2025
request titled “Request for Judicial Notice of Judicial
Misconduct.” That request was denied by the court, and
the court’s ruling thereon is not at issue in the pres-
ent appeal. The defendant also has not explained in his
brief the relevance of his allegations of prior judicial
misconduct to the proceedings relating to the August
2024 contempt motion. Accordingly, this argument is
inadequately briefed, and we decline to address it.
Furthermore, the defendant repeatedly argues that
the court exhibited bias by misrepresenting the defen-
dant’s testimony concerning the age of the parties’ minor
child. Specifically, the defendant asserts that the court
misstated the age of the parties’ son as seventeen and
one-half years old. The defendant asserts that he has
“the authority to impose ‘driving rules’ on a sixteen year
old” and that the judge “twisted” his testimony. The
defendant does not cite to any evidence in the record to
support his claim that the parties’ son was sixteen years
11
This court’s decision in In re Tayquon H., supra, 76 Conn. App.
693, does refer to General Statutes § 45a-604 (5), which enumerates
the rights and responsibilities of a guardian of a minor. See id., 698.
To the extent that the defendant, although unartfully, intended to
refer to this statute, the defendant has not explained how that statute
is applicable to the present case, how the court’s ruling violated that
statute, or provided any other pertinent analysis of that provision.
Amelio v. Amelio
old at the time of the contempt hearings. To the contrary,
the plaintiff’s testimony that the parties’ son was sev-
enteen years old and turned eighteen years old in May
2025 supported the court’s finding that, as of December
2024, his age was seventeen and one-half years old. Nor
does the record indicate that the court mischaracterized
the defendant’s testimony, during which the following
colloquy occurred:
“The Court: Is [the parties’ son] sixteen or seventeen?
“[The Defendant]: He’s seventeen and a half.
“The Court: He’s seventeen and a half. Does he have
. . . a restricted license, or does he have a full license?
“[The Defendant]: He has a home where there’s
rules. . . .
“The Court: I understand.
“[The Defendant]: Are you . . . going to allow your
sixteen year old to drive anywhere he wants and you
have no say in it?
“The Court: He’s seventeen and a half. He’s not six-
teen, sir.
“[The Defendant]: No, that doesn’t matter.
“The Court: He’s seventeen and a half.
“[The Defendant]: He’s under eighteen. Your Honor,
I don’t appreciate how you’re spinning this.”
The defendant’s brief does not explain how the court
exhibited judicial misconduct by stating that the parties’
son was seventeen and one-half years old, particularly
when the defendant did not dispute that fact during the
December 2024 hearing. Because the defendant on appeal
provides conclusory statements without any relevant
citations to legal authorities or legal analysis to support
his assertion, we decline to review it.
Finally, the defendant asserts that the court excluded
“critical evidence concerning child safety,” but he has
Amelio v. Amelio
not provided any meaningful analysis of this claim. The
defendant argues that the court ignored certain “tragic
events,” including an alleged fatal crash involving a six-
teen year old child and an accident involving the parties’
daughter. At the December 2024 hearing, however, the
defendant did provide extensive testimony concerning
these incidents and how, in light of them, he wanted to
restrict his son’s driving privileges. The court recognized
the defendant’s concerns as genuine but nevertheless
rejected his claim.
On appeal, the defendant’s brief does not cite to any
legal principles that the court improperly failed to follow
with respect to its consideration of the evidence that the
defendant had offered concerning prior accidents involv-
ing minor children, nor does his brief explain, by way of
citations to case law or analysis, how the court’s ruling
on the August 2024 contempt motion was improper.
We conclude that the defendant’s mere assertion that
the court “ignored” his concerns is not supported by the
record before us and constitutes a mere invitation to
reweigh the evidence and testimony presented, which we
decline to do on appeal. See, e.g., Downing v. Dragone,
216 Conn. App. 306, 331, 285 A.3d 59 (2022) (“[t]his
court will not reweigh the evidence or resolve questions
of credibility” (internal quotation marks omitted)), cert.
denied, 346 Conn. 903, 287 A.3d 601 (2023).
Although we recognize that the defendant is self-rep-
resented, “the solicitous treatment we afford a self-rep-
resented party does not allow us to address a claim on his
behalf when he has failed to brief that claim.” (Internal
quotation marks omitted.) Stanley v. Scott, 222 Conn.
App. 301, 306, 304 A.3d 892 (2023), cert. denied, 348
Conn. 945, 308 A.3d 34 (2024). The defendant’s brief
simply is inadequate for us to conduct any meaningful
review of his claims, and we thus decline to review them.
The judgments are affirmed.
In this opinion the other judges concurred.