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F. S. v. J. S.

2026-08-25

Summary

Holding. The trial court did not abuse its discretion in denying the defendant's motion for leave to file a motion to modify existing visitation orders, as the court properly accounted for the best interest of the child standard when it found the defendant failed to establish probable cause for modification. The judgment was affirmed.

A divorced father appealed the trial court's denial of his request to file a motion seeking modification of existing parental access orders. The father argued that the court failed to properly apply the best-interest-of-the-child standard when it rejected his request. The appellate court examined whether the trial court abused its discretion in denying permission to file the modification motion. The court found that the father had not met the prerequisites set by the original dissolution judgment, which required him to demonstrate compliance with existing orders—including engaging in court-ordered treatment and exercising at least 75 percent of his parenting access—before seeking modification. The trial court had explained these requirements to the father at a hearing and found he failed to establish probable cause for modification.

The appellate court concluded that the trial court properly considered the best-interest standard. The court reasoned that based on the trial judge's instructions at the hearing, the judge understood the significance of the best-interest-of-the-child standard. In the absence of contrary evidence, the appellate court presumed the trial judge had properly weighed all evidence and applied the correct legal standard when denying the request.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether the trial court abused its discretion by denying leave to file a motion for modification of visitation orders
  • Whether the court properly applied the best-interest-of-the-child standard in evaluating probable cause for modification
  • Whether the defendant met the conditions precedent for seeking modification established in the original dissolution judgment

Procedural posture

The defendant appealed from the trial court's denial of his motion for leave to file a motion to modify an existing parental access order in a previously dissolved marriage action.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

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F. S. v. J. S.

F. S. v. J. S.*

(AC 48280)

Alvord, Westbrook and DiPentima, Js.

Syllabus

The defendant, whose marriage to the plaintiff previously had been dissolved, appealed from the trial court’s judgment denying his postjudgment motions for leave to file, inter alia, a motion for modification of an existing order governing his parental access to the parties’ minor child. The defendant claimed, inter alia, that the court failed to account properly for the best interest of the child when it denied his motion to modify the existing visitation orders. Held:

The trial court properly accounted for the best interest of the child when it denied the defendant’s motion for leave to file a motion to modify the existing visitation orders, as the defendant failed to demonstrate that the court abused its discretion in that manner and, without any evidence to the contrary, this court presumed that the trial court properly considered the best interest standard in assessing whether the defendant had established probable cause for filing a motion to modify the existing visitation orders.

Argued February 4—officially released August 25, 2026

Procedural History

Action for the dissolution of a marriage, and for other

relief, brought to the Superior Court in the judicial

district of Hartford and tried to the court, Prestley, J.; judgment dissolving the marriage and granting certain

other relief in accordance with the parties’ separation

agreement; thereafter, the case was transferred to the

Regional Family Trial Docket; subsequently, the court,

Phoenix-Sharpe, J., denied the defendant’s motions for

leave to file, inter alia, a motion for modification of parental access orders and rendered judgment thereon, from

which the defendant appealed to this court. Affirmed.

*

In accordance with our policy of protecting the privacy interests of the victims of family violence, we decline to use the parties’ full names or to identify the victims or others through whom the victims’ identities may be ascertained. See General Statutes § 54-86e.

Moreover, 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.

F. S. v. J. S.

J. S., self-represented, the appellant (defendant).

Dennis Francis O’Toole, for the appellee (plaintiff).

Opinion

PER CURIAM. The defendant, J. S., whose marriage

to the plaintiff, F. S., was dissolved in 2018, appeals from postjudgment orders of the trial court denying his motion for leave to file a motion for modification of an existing order governing his parental access to the parties’ minor child; his motion for leave to file a motion seeking the disclosure of certain medical records; and various additional motions for leave to file motions seeking reargument,

reconsideration and clarification of the aforementioned

rulings.1 The defendant claims on appeal that (1) the

trial court has and continues to violate his due process

rights, in particular with respect to rights the defendant asserts under the Americans with Disabilities Act of

1990, 42 U.S.C. § 12101 et seq. (2024); (2) the existing

order requiring him to use a supervised visitation agency at his own cost is unconstitutional; (3) the court’s denial of his requests to file motions is unconstitutional and in retaliation for a federal lawsuit that he filed against the Judicial Branch and several judges who have acted in this dissolution action; (4) the requirement that the defendant engage in therapy as a condition of visitation with

the child is improper given that he has not been found to pose a risk of injury to the child; (5) the court’s refusal to allow him to move for modification of the existing

parental access orders violates the best interest of the

child in light of the fact that he has not had visitation for more than three years; (6) the court effectively has

sealed the defendant’s own medical records from him;

and (7) the courts of this state routinely discriminate

1

Early on in this action, due to the sheer volume of repetitive and frivolous motions being filed by the parties—most notably by the defendant—the trial court issued an order requiring the parties, with some exceptions, to seek permission of the court before filing additional motions. This court upheld the propriety of that order in the defendant’s previous appeal. See F. S. v. J. S., 223 Conn. App. 763, 796–98, 310 A.3d 961, cert. denied, 350 Conn. 903, 323 A.3d 344 (2024).

F. S. v. J. S.

against men.2 Having thoroughly reviewed the record

and briefs of the parties, we conclude that the majority

of the claims and arguments raised by the defendant in

support thereof are not properly before us, not adequately briefed, or previously have been addressed and rejected

by this court in the defendant’s prior appeal. See F.

S. v. J. S., 223 Conn. App. 763, 310 A.3d 961, cert.

denied, 350 Conn. 903, 323 A.3d 344 (2024). Because we

are not convinced on the present record that the court

abused its discretion by denying the defendant’s various

motions for leave, we affirm the judgment of the court.

The only claim meriting further discussion concerns

whether the court, in denying the defendant’s request

to file a motion to modify the existing visitation orders, failed to account properly for the best interest of the

child. The defendant has failed to demonstrate that the

court abused its discretion in this manner.

The following facts and procedural history are relevant

to this claim. The trial court conducted a hearing on

the defendant’s motion for leave to modify the existing

visitation orders on July 18, 2024. The self-represented

defendant was permitted to offer testimony and argue

why the court should permit him to file his motion to

modify. In an effort to help the defendant to provide

the court with relevant testimony, the court explained

as follows: “[W]hen you file a motion for modification,

the court is going to be looking for either a material

change in circumstances, or that the modification that

you are requesting is in the best interest of the minor

child, or that . . . the existing orders are not in the best interest of the minor child.” After giving the defendant

an opportunity to make his case for why he should be

allowed to pursue modification, the court summarized

his arguments. When the court asked the defendant if

there was anything else he wanted to tell the court regarding why it should grant his request for leave to file his 2

The defendant’s brief, including his statement of the issues, is difficult to follow and repetitious. For clarity, we have combined and restated some of the defendant’s claims.

F. S. v. J. S.

motion for modification, the defendant responded, in

part, “because, Your Honor . . . it is in the best interest of the child.”

On October 10, 2024, the court issued an order denying the defendant’s motion for leave to file a motion

seeking modification of the court’s July 15, 2022 orders

regarding custody and visitation. After setting forth

the relevant provisions of the July 15, 2022 dissolution

judgment,3 the court first noted that the defendant had

failed to comply with that aspect of the July 15, 2022

judgment that required him to submit with any motion

requesting permission to seek modification a signed

and sworn affidavit or other representation that he had

exercised at least 75 percent of his parenting access or

engaged in required treatment for at least one year.

3

The July 15, 2022 judgment provided in relevant part: “The defendant’s parenting access shall begin once he has provided proof to the plaintiff and/or her counsel of record that he is engaged with a clinician who has the skills and training to address narcissistic personality disorder. The defendant shall provide proof of his engagement in treatment to the plaintiff and/or her counsel of record on a quarterly basis. . . .

“The defendant’s access shall not be expanded or modified until a motion to modify has been filed to the court with a request for leave and a showing that he has exercised at least 75 percent of his parenting access and engaged in regular and consistent treatment for at least one year, which includes, but is not limited to, the following: a clinician who has the skills and training to address narcissistic personality disorder; consultation with a psychiatrist and neurologist; and group therapy for domestic abuse/trauma. . . .

“Any motion to modify the parenting access by the defendant shall include a request for leave and a signed and sworn to affidavit.”

In his prior appeal challenging the court’s July 15, 2022 judgment, the defendant did not directly challenge the court’s order limiting the defendant’s right to seek modification or expansion of his parenting access. “It is well established that when a party brings a subsequent appeal, [he] cannot raise questions [that] were or could have been answered in [his] former appeals. . . . Failure to raise an issue in an initial appeal to this court constitutes a waiver of the right to bring the claim.” (Citation omitted.) Detar v. Coast Venture XXVX, Inc., 91 Conn. App. 263, 266, 880 A.2d 180 (2005). Moreover, once this court has considered a judgment on appeal, any aspect of the judgment that is not reversed “establishes the law of the case,” adherence to which “is equally obligatory upon the parties to the action and upon the trial court.” (Internal quotation marks omitted.) Id., 267.

F. S. v. J. S.

The court also concluded that many of the arguments

relied on by the defendant had been raised in his appeal

from the dissolution judgment, which had resulted in

an affirmation of the trial court’s July 15, 2022 orders. The court expressly recognized the defendant’s argument that “modification is required in the best interest

of the minor child.” The court concluded, however, that

the defendant had failed to allege or otherwise provide

evidence of his compliance with the July 15, 2022 orders

regarding his parental access to the child or regarding

modification of his parental access. Although the court

recognized that the defendant had not seen the child for

more than two years, the court attributed this, at least in part, to the defendant’s failure to comply with the court’s July 15, 2022 orders. The court concluded: “Given all

of the foregoing, and based on the court’s review of the

file, testimony of the parties, and representations from

counsel, the court does not find that the defendant has

established probable cause for his underlying motion.”

In assessing whether to allow a party to file a motion in a case in which the court has issued a prohibitory order

barring the filing of motions without prior authorization of the court, the moving party has the burden of demonstrating that there is probable cause that grounds exist

for the motion to be granted. See, e.g., Practice Book

§ 25-26 (g). It is axiomatic that the touchstone of any

determination regarding custody and visitation is what

is in the best interest of the child. See F. S. v. J. S., supra, 223 Conn. App. 793; see also Ridgeway v. Ridgeway,

180 Conn. 533, 541, 429 A.2d 801 (1980) (“in matters

involving child custody, and, by implication, visitation

rights, [although] the rights, wishes and desires of the

parents must be considered it is nevertheless the ultimate welfare of the child [that] must control the decision of the court” (internal quotation marks omitted)). In making or

modifying orders pertaining to the custody and care of

minor children in dissolution actions, court are guided

by General Statutes § 46b-56, which grants the court

broad discretion in crafting such orders. Subsection (a)

of § 46b-56 provides in relevant part that “the court may

F. S. v. J. S.

assign parental responsibility for raising the child to the parents jointly, or may award custody to either parent

or to a third party, according to its best judgment upon

the facts of the case and subject to such conditions and

limitations as it deems equitable. . . .” Subsection (b) of § 46b-56 provides in relevant part that, “[i]n making . . . any order as provided in subsection (a) of [§ 46b-56], the rights and responsibilities of both parents shall be considered and the court shall enter orders accordingly that serve the best interests of the child and provide the child with the active and consistent involvement of both parents commensurate with their abilities and interests. . . .” (Emphasis added.) “The court may consider many factors in determining whether modification of custody

and visitation is in [a child’s] best interests and, in the absence of evidence to the contrary, we presume that the

court properly weighed all the evidence before it.” D. K. v. D. F., 235 Conn. App. 59, 72, 344 A.3d 564 (2025).

Having reviewed the transcript of the hearing on the

defendant’s motion, we reasonably may infer from the

court’s instructions to the defendant at the hearing

about what he would need to show to successfully move

for modification of the existing custody and visitation

orders that the court understood the significance of the

best interest of the child standard in evaluating whether the defendant had met his burden of showing probable

cause for filing a motion for modification at that time.4 Moreover, without any evidence to the contrary, we

presume that the court properly considered the best

interest standard in assessing whether the defendant had

established probable cause for filing a motion to modify

the current visitation orders.

The judgment is affirmed.

4

Nothing precludes the defendant from seeking permission to file a motion for modification of custody and/or visitation in the future, particularly once he has satisfied the conditions set forth in the dissolution judgment, has made reasonable efforts to do so, or has provided some evidence demonstrating that a substantial change in circumstances warrants the court’s revisiting its prior order.