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C. P. v. Riordan
C. P. v. CAROL RIORDAN*
(AC 48829)
Clark, Westbrook and Wilson, Js.
Syllabus
The defendant appealed from the trial court’s judgment granting the plaintiff’s application for an order of civil protection on the basis of stalking. The defendant claimed, inter alia, that the court improperly concluded that the plaintiff had met her burden of establishing that she was entitled to the order of civil protection pursuant to statute (§ 46b-16a). Held:
The trial court did not abuse its discretion in finding that the plaintiff proved the necessary elements under § 46b-16a for the issuance of an order of civil protection, as the court credited the plaintiff’s testimony that she feared for her physical safety, which established the subjective prong of the fear analysis under § 46b-16a, the content and repetitive nature of the defendant’s emails to the plaintiff, in combination with her menacing behavior while driving past the plaintiff, were sufficient for the court to conclude that a person in the plaintiff’s position would reasonably fear for her personal safety, which established the objective prong of the fear analysis under § 46b-16a, and the defendant’s recent conduct, in sending emails to the plaintiff and menacing the plaintiff, was sufficient for the court to find that the defendant would continue to stalk the plaintiff if a civil order of protection was not granted.
The trial court did not abuse its discretion when it precluded the defendant from testifying regarding her claim that the plaintiff had allegedly harassed her, as the defendant offered the evidence to prove only that she was not delusional, which was irrelevant to the court’s determination of whether the plaintiff’s application for an order of civil protection should be granted and, therefore, was inadmissible.
This court declined to review the defendant’s claim that the trial court’s issuance of the order of civil protection violated her right to free speech under the first amendment to the United States constitution and under article first, §§ 4, 5 and 14, of the Connecticut constitution, as the defendant failed to adequately brief that issue.
Argued April 16—officially released July 21, 2026
Procedural History
Application for a civil protection order, brought to the
Superior Court in the judicial district of Middlesex and
*
In accordance with federal law; see 18 U.S.C. § 2265 (d) (3) (2024); we decline to identify any person protected or sought to be protected under a protection order, protective order, or a restraining order that was issued or applied for, or others through whom that person’s identity may be ascertained.
C. P. v. Riordan
tried to the court, Baldini, J.; judgment granting the
application and issuing an order of civil protection, from
which the defendant appealed to this court. Affirmed.
Terry Donovan, with whom was Jeremiah Donovan,
for the appellant (defendant).
Matthew S. Blumenthal, for the appellee (plaintiff).
Opinion
WESTBROOK, J. The defendant, Carol Riordan,
appeals from the judgment of the trial court granting
the application of the plaintiff, C. P., for an order of civil protection pursuant to General Statutes § 46b-16a1 on the
basis of stalking. On appeal, the defendant claims that
the trial court improperly (1) found that the plaintiff
met her burden of establishing that she was entitled to
an order of civil protection pursuant to § 46b-16a,2 (2)
excluded the defendant’s testimony as irrelevant, and
1
General Statutes § 46b-16a (a) provides: “Any person who has been the victim of sexual abuse, sexual assault or stalking may make an application to the Superior Court for relief under this section, provided such person has not obtained any other court order of protection arising out of such abuse, assault or stalking and does not qualify to seek relief under section 46b-15. As used in this section, ‘stalking’ means two or more wilful acts, performed in a threatening, predatory or disturbing manner of: Harassing, following, lying in wait for, surveilling, monitoring or sending unwanted gifts or messages to another person directly, indirectly or through a third person, by any method, device or other means, that causes such person to reasonably fear for his or her physical safety.”
2
In her appellate brief, the defendant claims that the trial court improperly concluded that the plaintiff established the elements required by § 46b-16a (a) and (b). She also claims that the court improperly found that the plaintiff established that the defendant would continue to stalk the plaintiff. See General Statutes § 46b-16a (b) (“[i]f the court finds that there are reasonable grounds to believe that the respondent has committed acts constituting grounds for issuance of an order under this section and will continue to commit such acts, or acts designed to intimidate or retaliate against the applicant, the court, in its discretion, may make such orders as it deems appropriate for the protection of the applicant”). Although the defendant has briefed these claims separately, each, in fact, concerns an element required to be proved by § 46b-16a (a) and (b). Therefore, we will address these claims together as separate arguments in support of a singular claim as we have restated it.
C. P. v. Riordan
(3) issued an order of civil protection in violation of her right to free speech under the first amendment to the
United States constitution and article first, §§ 4, 5 and
14, of the Connecticut constitution. We disagree and,
accordingly, affirm the judgment of the trial court.
The court, Baldini, J., found the following facts in
support of its decision to grant the plaintiff’s application for an order of civil protection. The plaintiff formerly
served as a member of the Connecticut legislature and
left office on January 8, 2025. The defendant was both
her neighbor and constituent; however, the defendant
has since moved.
On October 6, 2023, the defendant made “[a]n unwanted
visit . . . [to the plaintiff’s] home at 6 [a.m.] or so in the morning, after [the defendant] had texted her at 3 a.m.”
After this visit, “[the plaintiff] asked the [defendant] not to contact her . . . . This was communicated to the . . .
[defendant] via text. This request was received by the
[defendant], as indicated by the [defendant’s response]
in both an email and a text.” In the defendant’s October
10, 2023 email, she stated, “I certainly will honor your
wishes in terms of avoiding contact.”
After the plaintiff informed the defendant of her
wishes, the defendant, nonetheless, contacted the plaintiff on multiple occasions throughout February 2025,
after the plaintiff had left political office. During this
period, the defendant sent four emails to the plaintiff’s
personal email address. The February 11, 2025 email
stated, in relevant portion, “lovely to run into you yesterday . . . . I had been thinking of you because your associate . . . has been in touch with me”; the February 12, 2025
email contained the phrase “police services”; the February 15, 2025 email stated, “phones have been analyzed”
and “it is only a matter of time”; and the last email, from February 16, 2025, stated, “Retaliation and harassment”
in its subject line. Additionally, around this time, the
defendant “revv[ed] her [car’s engine] and blar[ed] her
horn, while driving [in the direction of the plaintiff] on a residential street.” Additionally, the defendant “falsely
C. P. v. Riordan
accused [the plaintiff] of doing things that [the plaintiff] did not do, namely hiring shadowy figures, hacking her
email, [and] hiring people to trail her.”
The court, in its May 28, 2025 oral decision, concluded
that the plaintiff carried her burden of proof and found
that “[t]here’s evidence that acts constituting . . . harassing, following, lying in wait for, surveilling or monitoring or sending unwanted gifts or messages to another
person directly, indirectly, or through a third person,
by any method, device, or means . . . were performed in
a . . . threatening, predatory, or disturbing manner,”
and that these actions could reasonably result in the
plaintiff feeling fear. The court, having “evaluated [the
plaintiff’s] claimed fear using the subjective objective
standard” and having considered whether the defendant
was likely to continue stalking, pursuant to § 46b-16a,
granted the plaintiff’s application for an order of civil
protection. This appeal followed.
I
We first address the defendant’s claim that the trial
court abused its discretion in granting the plaintiff’s
application for an order of civil protection. The defendant argues that the court improperly found that the plaintiff
met her burden of establishing that she was entitled to
an order of civil protection pursuant to § 46b-16a. We
disagree.
We begin by setting forth the applicable standard
of review and legal principles that are relevant to our
resolution of the defendant’s claim. “We apply the same
standard of review to civil protection orders under § 46b16a as we apply to civil restraining orders under General Statutes § 46b-15.3 Thus, we will not disturb a trial
court’s orders unless the court has abused its discretion or it is found that it could not reasonably conclude as it did, based on the facts presented. . . . In determining whether
a trial court has abused its broad discretion . . . we allow every reasonable presumption in favor of the correctness
3
See L. H.-S. v. N. B., 341 Conn. 483, 486, 489, 267 A.3d 178 (2021).
C. P. v. Riordan
of its action. . . . Appellate review of a trial court’s findings of fact is governed by the clearly erroneous standard
of review. . . . A finding of fact is clearly erroneous 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 committed. . . .
Our deferential standard of review, however, does not
extend to the court’s interpretation of and application
of the law to the facts. It is axiomatic that a matter of
law is entitled to plenary review on appeal.” (Footnote
added; internal quotation marks omitted.) S. S. v. D. M.,
228 Conn. App. 559, 562–63, 324 A.3d 233 (2024).
“[A]n applicant for a civil protection order on the basis
of stalking [pursuant to § 46b-16a] is required to prove
only that there are reasonable grounds to believe that a
defendant stalked and will continue to stalk . . . . A finding of reasonable grounds to believe stalking occurred is
equivalent to a finding of probable cause that stalking
occurred. . . . While probable cause requires more than
mere suspicion . . . the line between mere suspicion and
probable cause necessarily must be drawn by an act of
judgment formed in light of the particular situation
and with account taken of all the circumstances. . . . The
existence of probable cause does not turn on whether the
defendant could have been convicted on the same available evidence. . . . In dealing with probable cause . . .
as the very name implies, we deal with probabilities.”
(Citations omitted; footnote omitted; internal quotation marks omitted.) C. A. v. G. L., 201 Conn. App. 734,
740–41, 243 A.3d 807 (2020).
“In order for a court to issue an order of civil protection under § 46b-16a on the basis of stalking, it must
find that there are reasonable grounds to believe that the
defendant both stalked the plaintiff and will continue to
commit such acts. . . . If a court issues an order without a proper finding or without sufficient evidence to support
such a finding, as to either stalking or the continuation
of such acts, it will constitute an abuse of discretion.”
C. P. v. Riordan
(Citations omitted.) S. B-R. v. J. D., 208 Conn. App. 342,
347–48, 266 A.3d 148 (2021).
“Stalking for purposes of obtaining a civil protection
order . . . covers a . . . [broad] range of prohibited actions. Section 46b-16a (a) provides in relevant part: ‘As used in
this section, “stalking” means two or more wilful acts,
performed in a threatening, predatory or disturbing
manner of: Harassing, following, lying in wait for, surveilling, monitoring or sending unwanted gifts or messages to another person directly, indirectly or through
a third person, by any method, device or other means,
that causes such person to reasonably fear for his or her
physical safety.’ Thus . . . [to] trigger a civil protection order, the plaintiff needed only to allege and prove that,
on two occasions, the defendant harassed, surveilled or
monitored her in a manner that reasonably caused her
to fear for her physical safety.” S. A. v. D. G., 198 Conn. App. 170, 190, 232 A.3d 1110 (2020).
Furthermore, our Supreme Court has established that
the test to determine whether a plaintiff has experienced
fear sufficient to induce an order of civil protection has
both subjective and objective components. “[T]o establish fear, the plaintiff [is] required to establish that she subjectively feared for her personal safety. Additionally,
‘such person[’s]’ fear must be ‘reasonabl[e] . . . .’ General Statutes § 46b-16a (a). This language adds an objective
requirement.” L. H.-S. v. N. B., 341 Conn. 483, 494, 267
A.3d 178 (2021). Put differently, “the situation and the
facts must be evaluated from the perspective of the victim, i.e., did [she] in fact fear for [her] physical safety. . . . If so, that fear must be objectively reasonable, i.e., a reasonable person under the existing circumstances would
fear for his or her personal safety.” S. S. v. D. M., supra, 228 Conn. App. 566.
On the basis of our review of the record, we conclude
that, in the present case, the trial court did not abuse
its discretion in finding that the plaintiff proved the
necessary elements under § 46b-16a. After the defendant’s unwanted appearance at the plaintiff’s door in
C. P. v. Riordan
the early morning hours of October 6, 2023, and after
the plaintiff stated her displeasure with the contact,
the defendant said that she would no longer contact the
plaintiff. Almost immediately, however, she continued to
contact the plaintiff by email. Later, in 2025, one month
after the plaintiff resigned from her position as a state
representative, the defendant’s emails caused the plaintiff to feel threatened, and the court subsequently found
that they were disturbing. In the defendant’s February
11, 2025 email, after accusing the plaintiff of colluding
with someone whom the defendant says “gunned [his]
vehicle when parking so it came onto the sidewalk very
close to” her, she stated, “Maybe with your workplace
sensitivity and anti-harassment training expertise you
could work with him on his road rage? I’d appreciate it!”
She followed up with an email on February 12, 2025, that
stated, “[For your information], I am forwarding emails
to [local] Police Services and police services outside the
state. As they say, sunshine banishes the shadows.” Three
days later, the defendant sent another email stating that
“[t]he additional harassment on [February] 13 has been
duly noted. My phones have been analyzed. Now, it is
only a matter of time.” In her last email, on February 16,
2025, she made multiple allegations, including “official
misconduct,” “intense retaliation and harassment,”
“vandalism” to the defendant’s vehicle, and “hacks” of
the defendant’s online accounts. The plaintiff was also
menaced by the defendant after the defendant continuously honked her horn and revved her vehicle’s engine
at the plaintiff while driving past the plaintiff.
The court credited the plaintiff’s testimony that she
feared for her physical safety, which establishes the subjective prong of the fear analysis. See L. H.-S. v. N. B.,
supra, 341 Conn. 494 (“to establish fear, the plaintiff
[is] required to establish that she subjectively feared for her personal safety”). The court’s finding that the defendant’s actions were disturbing was reasonable. MerriamWebster’s Collegiate Dictionary defines “disturbing”
as “causing feelings of worry, concern, or anxiety . . . .” Merriam-Webster’s Collegiate Dictionary (12th Ed.
C. P. v. Riordan
2026) p. 481. Both the content and repetitive nature of
the defendant’s 2025 emails, in combination with the
defendant’s menacing behavior while driving past the
plaintiff, also were sufficient for the court to conclude
that a person in the plaintiff’s position would reasonably
fear for her personal safety.
We next address whether the defendant was likely to
continue stalking the plaintiff. The plaintiff was the
subject of the defendant’s stalking for one and one-half
years. The majority of her messages, although they
address a subject matter relating to actions taken by the
plaintiff in her capacity as a state representative, were
sent through nonofficial channels, such as the emails
sent to the plaintiff’s personal email address, the text
messages sent to the plaintiff’s personal phone number,
and a handwritten note the defendant attempted to place
on the plaintiff’s door. After the interaction between the
defendant and the plaintiff, which stemmed from the
defendant’s attempt to leave the note on the plaintiff’s
door, the defendant appeared to understand that the
plaintiff did not want to be contacted by the defendant
again. Despite this understanding, which was clearly
established in the defendant’s October 10, 2023 email to
the plaintiff, the defendant, within a short amount of
time, initiated communication with the plaintiff again.
This communication, although it slowed at times, never
ceased. In fact, the February 2025 emails illustrate the
frequency with which the defendant sent these messages. The combination of the recent emails and the
recent menacing of the plaintiff was enough for the court
to find that the defendant would continue to stalk the
plaintiff if the application for a civil order of protection was not granted.
We conclude, on the basis of our thorough review of
the record, that the trial court did not abuse its discretion by granting the plaintiff’s application for a civil
order of protection on the basis of stalking pursuant
to § 46b-16a. The plaintiff received multiple unwanted
emails and texts from the defendant over the course of
C. P. v. Riordan
one and one-half years, ultimately prompting her to
file her application for a civil order of protection. The
record supports the trial court’s determination that the
defendant was likely to continue stalking the plaintiff
on the basis of her previous behavior. We conclude that
the trial court did not abuse its discretion in granting
the application for an order of civil protection.
II
Next, we address the defendant’s claim that the trial
court abused its discretion when it improperly precluded
her from testifying about alleged harassment by the
plaintiff. We disagree.
The following additional facts are relevant to our
resolution of this claim. At the initial hearing for the
application for an order of civil protection, during direct examination of the defendant, the defendant’s counsel
attempted to elicit testimony that the defendant was
being stalked and harassed because of alleged actions
taken by the plaintiff. The court attempted to determine
how this evidence was relevant to the application before
it, which resulted in the following colloquy:
“The Court: She’s saying she’s a victim of stalking.
“[The Defendant’s Counsel]: Yes, Your Honor.
“The Court: By who?
“[The Defendant’s Counsel]: . . . [S]he’s of the belief
that [the plaintiff] has caused the surveillance of her
home . . . .
“The Court: Okay. Well . . . [the plaintiff] is the applicant for a civil restraining order. . . . [The defendant] is not, [the defendant] is the respondent.”
After further discussion, the trial court was able to
determine that the defendant’s counsel elicited this
testimony to establish that the defendant herself was
“being stalked and followed . . . .” The court then asked
the defendant’s counsel if she was attempting to establish
that the plaintiff was the person stalking the defendant,
C. P. v. Riordan
which could have undermined the plaintiff’s credibility.
The defendant’s counsel responded, “No. It’s that [the
plaintiff] has characterized . . . the [defendant] . . . [as] delusional . . . .” It was the defendant’s belief that, if
she could establish that she was the subject of stalking, then she could prove that she is not delusional. The
court responded, “if she feels that she’s being stalked
and followed, there is no application by her in front of
this court.”
In the defendant’s memorandum in support of her
motion to reargue, she argues that the court improperly
found “that testimony by the [defendant] concerning
the fact that she . . . has been the victim of stalking and vandalism ‘doesn’t have relevance to this proceeding’ . . . when the [defendant] has reason to believe that those acts
may have been committed at the behest of the [plaintiff].”
(Citation omitted.) At the hearing on the motion, however, the defendant’s counsel argued that “there were
other things that my client wanted to testify to, that
she didn’t get to testify to.” For example, “[s]he would
have addressed the fact that it wasn’t just that the police were sent to surveil her, it was that she had been stalked
by someone—a couple of different people had been following her around. And someone had tampered twice,
at separate occasions, with her car. . . . [S]he wanted to
testify about the details of that. . . . And that, that’s why she wasn’t being delusional . . . .”
The court responded that “the point of the matter is
. . . that I asked you, specifically, is she accusing [the
plaintiff] of [stalking her]? Because that would go to the
heart of the very issue of [the plaintiff’s] credibility. . . . But . . . [y]ou said, no . . . we want to introduce this
evidence to show that she’s not delusional.” The defendant’s counsel stated that she had responded as such to
the court’s question because she was arguing that the
plaintiff directed others to follow the defendant and was
not doing so herself. The court noted, however, that the
defendant’s counsel had an opportunity to cross-examine
the plaintiff to elicit the very testimony she sought to
C. P. v. Riordan
elicit from the defendant. At the close of the hearing,
the trial court ruled in favor of the plaintiff and upheld
its previous ruling granting the application for a civil
order of protection.
“Evidentiary rulings in relation to a civil order of
protection are reviewed under the same well established
standard as in other cases. . . . [R]elevant evidence is
evidence that has a logical tendency to aid the trier in
the determination of an issue. . . . Evidence is irrelevant or too remote if there is such a want of open and visible
connection between the evidentiary and principal facts
that, all things considered, the former is not worthy or
safe to be admitted in the proof of the latter. . . . The trial court has wide discretion to determine the relevancy of
evidence and [e]very reasonable presumption should be
made in favor of the correctness of the court’s ruling
in determining whether there has been an abuse of discretion.” (Citation omitted; internal quotation marks
omitted.) L. H.-S. v. N. B., supra, 341 Conn. 501–502.
“Relevance does not exist in a vacuum. . . . Relevant
evidence, according to § 4-1 of the Connecticut Code of
Evidence, is evidence having any tendency to make the
existence of any fact that is material to the determination of the proceeding more probable or less probable
than it would be without the evidence. . . . To determine
whether a fact is material . . . it is necessary to examine the issues in the case, as defined by the underlying substantive law, the pleadings, applicable pretrial orders,
and events that develop during the trial. Thus, the relevance of an offer of evidence must be assessed against
the elements of the cause of action, crime, or defenses at
issue in the trial. The connection to an element need not
be direct, so long as it exists. Once a witness has testified to certain facts, for example, his credibility is a fact that is of consequence to [or material to] the determination
of the action, and evidence relating to his credibility is
therefore relevant—but only if the facts to which the
witness has already testified are themselves relevant to
an element of a crime, cause of action, or defense in the
C. P. v. Riordan
case.” (Internal quotation marks omitted.) S. A. v. D. G.,
supra, 198 Conn. App. 183–84.
Here, the testimony the defendant attempted to have
admitted through direct examination was not relevant
to the determination of whether the plaintiff’s application for a civil order of protection should be granted.
Accordingly, the trial court did not abuse its discretion by precluding the defendant from testifying with respect to
her claim that she was the subject of harassment. Section
46b-16a (a) requires a party seeking a civil order of protection, on the basis of stalking, to prove that such party was the subject of “two or more wilful acts, performed
in a threatening, predatory or disturbing manner . . . .”
See also S. A. v. D. G., supra, 198 Conn. App. 190. The
party must then establish that they felt fear as a result of the stalking and that the fear was objectively reasonable.
L. H.-S. v. N. B., supra, 341 Conn. 494. The party then
must establish that the stalking is likely to continue. See S. B-R. v. J. D., supra, 208 Conn. App. 347–48.
The evidence that the defendant sought to admit to
establish that she was being harassed and followed was
offered only to prove that she was not delusional. Significantly, the defendant expressly stated that she was not
offering the evidence to show that the plaintiff stalked
or harassed her and did not argue that the evidence was
being introduced to challenge the credibility of the plaintiff’s claim that she reasonably feared for her safety as a result of the defendant’s actions. Whether the defendant
was delusional in her belief that she was being stalked,
however, was completely irrelevant to the trial court’s
determination. Without any logical connection to the
issues properly before the court in ruling on the application for a civil order of protection, the evidence is not
relevant and is inadmissible. The trial court, therefore,
did not abuse its discretion by refusing to allow the defendant’s irrelevant testimony.
III
The defendant’s final claim is that the trial court’s
issuance of the civil order of protection violated her right
C. P. v. Riordan
to free speech under the first amendment to the United
States constitution and article first, §§ 4, 5 and 14, of
the Connecticut constitution. We decline to review this
claim because the defendant failed to adequately brief
the issue.
“We are not required to review issues that have been
improperly presented to this court 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. . . . [Simply put, we] do not reverse the judgment of a trial court on
the basis of challenges to its rulings that have not been
adequately briefed. . . . Our Supreme Court has recognized that adequate briefing is of particular importance
whenever the appellant is asserting a violation of his first amendment rights because of the analytical complexity of
such claims. See State v. Buhl, 321 Conn. 688, 726, 138
A.3d 868 (2016) (upholding Appellate Court’s decision
not to review first amendment and due process claims
because they were inadequately briefed). In Buhl, the
court quoted federal precedent for the proposition that
[f]irst [a]mendment jurisprudence is a vast and complicated body of law that grows with each passing day
and involves complicated and nuanced constitutional
concepts. . . . In considering the adequacy of briefing, it is proper for this court to consider, among other factors,
(1) whether the claim is stated clearly and succinctly
such that its contours can be understood by the court
and the opposing party, (2) the relative sparsity of any
analysis, meaning how much of the brief is dedicated to
the claim, (3) whether the analysis is confusing, repetitive [or] disorganized, and (4) whether the appellant has
cited, analyzed and applied relevant legal authority.”
(Citations omitted; internal quotation marks omitted.)
S. A. v. D. G., supra, 198 Conn. App. 191–92.
The defendant in the present case claims that “[t]he
court’s ruling is a grave and troubling threat to a citizen’s right to free speech, to criticize governmental
officials, to petition for redress of grievances, and to
C. P. v. Riordan
remonstrate against perceived governmental injustices.”
The defendant then presents the standard of review in a
manner that hints that her argument is that § 46b-16a,
on its face, is unconstitutional. The defendant states in
her brief that “[i]t is a ‘well established principle that
determining the constitutionality of a statute presents
a question of law subject to plenary review.’ ” At oral
argument, however, the defendant’s counsel claimed
that the statute is unconstitutional as applied to the
defendant. Thus, the defendant’s constitutional claim
is, at best, inconsistent, which makes it difficult, if not impossible, to discern the contours of her argument. See
Burton v. Dept. of Environmental Protection, 337 Conn.
781, 805, 256 A.3d 655 (2021) (holding that claim that
was internally inconsistent as briefed supported finding
of inadequate briefing).
Additionally, the defendant’s briefing of her constitutional claim is sparse, consisting of only five pages
of her forty-two page 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 inadequately
briefed. This is especially so with regard to first amendment and other constitutional claims, which are often
analytically complex.” State v. Buhl, supra, 321 Conn.
726; see also Cohen v. Rossi, 346 Conn. 642, 689, 295
A.3d 75 (2023) (holding that claim of error raising four
distinct arguments that was addressed in less than two
pages of brief was inadequately briefed).
The extent of the defendant’s analysis of her claim is
a one sentence paragraph that seemingly argues that
the defendant’s communications were simply remonstrances.4 Throughout her five pages of argument, the
defendant cites the United States constitution, the
4
“[The defendant] communicated with the . . . zoning officials, her state representative, and her first selectman, criticizing the town’s procedures in approving a major development and her state representative’s role in securing those approvals—if these communications were not ‘remonstrances,’ it is difficult to imagine what a ‘remonstrance’ might look like.”
C. P. v. Riordan
Connecticut constitution, and ostensibly relevant case
law. The defendant, however, fails to analyze this precedent and apply it to her claim. See Olson v. Freedom of
Information Commission, 238 Conn. App. 625, 631,
356 A.3d 452 (2026) (claim was inadequately briefed, as
plaintiff failed to provide analysis applying precedent
to facts). Although the defendant claims that her communication was simply a remonstration, she provides no
precedential support, which could tend to prove that the
speech engaged in was a remonstrance. This deficiency in
clarity supports our conclusion that the defendant has
inadequately briefed her constitutional claim.
On the basis of the foregoing, we conclude that the
defendant has inadequately briefed her claim. This court
is unable to ascertain what the precise alleged constitutional violation is and whether it deprived the defendant
of a fair trial. Accordingly, we decline to review the
defendant’s claim.
The judgment is affirmed.
In this opinion the other judges concurred.