Bolat v. Bolat

Opinion

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JEAN-PIERRE BOLAT v. YUMI S. BOLAT (AC 48507)

Suarez, Seeley and Palmer, Js.

Syllabus

The self-represented plaintiff, whose marriage to the defendant had previously been dissolved, appealed from, inter alia, the trial court’s judgment granting the defendant’s postjudgment motion for an educational support order and ordering the plaintiff to contribute to the college expenses of the parties’ youngest child for her last three semesters. The plaintiff claimed, inter alia, that the court improperly issued the order, as it failed to comply with the statutory (§ 46b-56c) requirements. Held:

The trial court did not deny the plaintiff his right to due process when, after argument by the parties, it concluded that it had subject matter jurisdiction to adjudicate the defendant’s motion for an educational support order, as the plaintiff’s motion to dismiss, which challenged the defendant’s fulfillment of the statutory prerequisites for the issuance of the order, was, in substance, an objection to the defendant’s motion, and the court properly overruled it.

The trial court did not abuse its discretion in issuing the educational support order, as the court properly applied the factors set forth in § 46b-56c to the facts of the case, it made extensive factual findings regarding the parties’ participation in their child’s college selection decision, which findings were supported by the record, it expressly stated that it had considered the relevant § 46b-56c factors, including the parties’ income, assets and debts, the child was not required to provide the plaintiff with all of her academic records as a prerequisite to the issuance of the order, and the plaintiff’s assertion that the order was impermissibly vague failed, as § 46b-56c does not require the level of specificity that the plaintiff claimed.

This court declined to review the plaintiff’s claims that the trial court’s issuance of the educational support order violated his constitutional rights, as those claims were inadequately briefed.

Argued May 21—officially released September 15, 2026

Procedural History

Action for the dissolution of a marriage, and for other relief, brought to the Superior Court in the judicial district of New Haven, where the court, Abery-Wetstone, J., rendered judgment dissolving the marriage in accordance with the parties’ separation agreement; thereafter, the court, Nastri, J., rendered judgment granting the defendant’s postjudgment motion for an educational support order, from which the plaintiff appealed to this court. Affirmed.

Jean-Pierre Bolat, self-represented, the appellant (plaintiff).

Richard W. Callahan, for the appellee (defendant).

Opinion

SEELEY, J. In this postjudgment dissolution matter , the self-represented plaintiff, Jean-Pierre Bolat, appeals from the judgment of the trial court granting the motion filed by the defendant, Yumi S. Bolat, for an educational support order pursuant to General Statutes § 46b-56c,1 and overruling the plaintiff’s objection thereto. On appeal, the plaintiff claims that the court improperly (1) treated his motion to dismiss as an objection to the defendant’s motion, (2) issued the educational support order on the basis that it failed to comply with § 46b-56c, and (3) violated his constitutional rights.2 We affirm the judgment of the trial court.

The following facts, as found by the trial court or otherwise undisputed, and procedural history guide our resolution of the plaintiff’s appeal. The plaintiff and the defendant were married on September 21, 1998, and have three children together. Their marriage was dissolved on June 21, 2011.3 The court incorporated into the judgment of dissolution a separation agreement signed by the parties on June 21, 2011 (separation agreement).

The separation agreement provided in relevant part: “The parties agree that if they had remained an intact family, the parties would have contributed to the post secondary education costs of the minor children to the 1 Since the court rendered judgment dissolving the parties’ marriage in June 2011, § 46b-56c has been the subject of several amendments that are not relevant to this appeal. See Public Acts 2011, No. 11-214, § 6; Public Acts 2015, No. 15-71, § 80; Public Acts 2021, No. 21-104, § 19; Public Acts 2022, No. 22-123, § 40. In the interest of simplicity, we refer to the current revision of the statute.

2 See footnote 17 of this opinion. 3 The three children subsequently attained the age of majority.

best of their abilities. The parties agree that a motion for educational support order in accordance with . . . § 46b- 56c may be filed by either party at a later date. The parties agree that the court shall retain continuing jurisdiction to enter an educational support order in accordance with the provisions of . . . § 46b-56c upon motion by a party pursuant to § 46b-56c (b) (1).”

Both parties subsequently remarried. The plaintiff has a stepchild, and the defendant has two stepchildren. The parties remained “engaged in high conflict litigation . . . . On at least one occasion in their tumultuous postdivorce relationship, [the plaintiff] instructed [the defendant] not to contact him or his current wife in any way.” (Footnote omitted.)

On January 8, 2024, the defendant filed a motion for an order seeking, inter alia, that the court enter an educational support order with respect to the parties’ youngest child.4 On February 20, 2024, the plaintiff filed a motion captioned “plaintiff’s postjudgment motion to dismiss.” Therein, the plaintiff alleged that the defendant had acted unilaterally without consulting him regarding the child’s choice of higher education and that “no evidence exists that the defendant complied with the prerequisites ” of § 46b-56c. (Emphasis omitted.) With respect to the defendant’s claim for educational support, the plaintiff requested as relief that the motion be dismissed on the grounds of “[f]ailure to abide by statutory requirements and . . . lack of diligence: failure to abide by statutory requirements.” The plaintiff attached to the motion a memorandum of law in support and his own affidavit.

On November 19, 2024, the parties appeared before the court, Nastri, J., at which time the court noted that there were two motions on its docket, the defendant ’s motion for order and the plaintiff’s motion to dismiss. The court explained that it would start with 4 The defendant also requested in her motion that the court “enter an order enforcing a prior court order for the plaintiff to pay sums due and owing to the defendant under the court’s orders.” See footnote 6 of this opinion.

the defendant’s motion. The plaintiff then requested that the court hear his motion first on the basis that it implicated the subject matter jurisdiction of the court. The defendant’s counsel responded that the plaintiff’s motion did not implicate subject matter jurisdiction. The plaintiff responded that the court lacked jurisdiction over the defendant’s motion because she had not satisfied the statutory requirements for an educational support order. After hearing argument from both parties , the court stated that it did not read the plaintiff’s motion as attacking the subject matter jurisdiction of the court but, rather, as asserting that the defendant had not met the statutory criteria, which, the court noted, was “a subject of evidence.” Accordingly, the court stated that it would permit the defendant’s counsel to proceed with the defendant’s motion seeking court orders and then would allow the plaintiff to “put [his] case on.” The plaintiff again reiterated his argument, at which time the court stated to the plaintiff that it had made its ruling. Thereafter, the hearing proceeded with respect to the defendant’s motion. Both parties testified and introduced documentary evidence. At the conclusion of evidence, following the court’s order regarding the filing of posthearing briefs, the following colloquy occurred:

“[The Plaintiff]: . . . [A]nd also, regarding the motion to dismiss. I know you wanted to hear this one first. Are we going to hear that one or did we quickly hear that one and you overruled it, denied?

“The Court: I overruled it. “[The Plaintiff]: Okay. “The Court: So, we’ll move forward on the underlying motion.”

The parties filed simultaneous posthearing briefs in December 2024, as ordered by the court. On February 5, 2025, the court issued its memorandum of decision. The court first addressed the motion filed by the plaintiff . The court noted that, although it was styled as a motion to dismiss, it did not challenge the jurisdiction of the court but, rather, argued that the defendant had “failed to abide by specified statutory requirements, failed to properly file a motion to open, and lacked diligence .” The court stated that it accordingly had treated the plaintiff’s motion as an objection to the defendant’s motion and had overruled it.

Turning to the defendant’s motion for an educational support order, the court first noted that the parties had provided in their separation agreement that they would have contributed to the children’s postsecondary education had they remained an intact family. With respect to the parties, the court found that “[i]t was very important to [the plaintiff], a devout Roman Catholic, that the parties’ children be raised in that faith. Both parties are highly educated. They each have a college degree. [The plaintiff] also has a master’s degree in business administration ; [the defendant] recently returned to college to become a registered nurse.”

The court found that the parties’ oldest and middle children had attended the University of Connecticut and College of the Holy Cross, respectively. The court found that, rather than seeking contributions from the plaintiff, the defendant had taken out loans to pay for the oldest child’s expenses that exceeded the financial awards received by the child. The court found that the middle child had obtained scholarships through the Reserve Officer Training Corps and, thus, neither parent contributed financially to his education. With respect to the parties’ youngest child, who was twenty-one years old at the time of the hearing, the court found that she “was the valedictorian of her high school graduation class. She chose to matriculate at Georgetown University, the oldest Catholic institution of higher education in the United States, run by the Jesuits , a Roman Catholic order of priests and brothers. . . . [The child] advised both [of] her parents of her decision to attend Georgetown University, where she has excelled academically. At the time of trial, [the child] was on the verge of completing the first semester of her senior year with a grade point average of 3.9. Her goal is to complete her college education as the valedictorian of her graduating class.

“During [the child’s] freshman and sophomore years at Georgetown University, she received significant merit and need based grants and scholarships. [The child’s] financial aid was substantial because the parties were able to list their two sons, plus [the defendant’s] two stepsons, on [the child’s Free Application for Federal Student Aid], resulting in a determination that the parties collectively had a reduced ability to help [the child] with her college expenses. That determination changed in [the child’s] junior year because her siblings and stepsiblings had completed their college educations, thereby increasing her parents’ ability—at least on paper—to contribute to [the child’s] other college expenses.

“Once [the child’s] grants and scholarships were reduced, [the defendant] determined she could no longer manage [the child’s] college expenses without a contribution from [the plaintiff].” (Citation omitted; footnotes omitted.) The defendant sought to have the plaintiff contribute financially to the child’s final three semesters at Georgetown University in accordance with § 46b-56c (g), which limits expenses to no more “than the amount charged by The University of Connecticut for a full-time in-state student,”5 a limitation commonly referred to as the UConn cap.

The court found that the parties did not participate in or agree upon the college the child would attend. The court considered and rejected the plaintiff’s efforts to 5 General Statutes § 46b-56c (g) provides: “The educational support order may include support for any necessary educational expense, including room, board, dues, tuition, fees, registration and application costs, but such expenses shall not be more than the amount charged by The University of Connecticut for a full-time in-state student at the time the child for whom educational support is being ordered matriculates, except this limit may be exceeded by agreement of the parents. An educational support order may also include the cost of books and medical insurance for such child.”

blame the defendant for the parties’ lack of agreement. The court found that the defendant had no reason to believe that the plaintiff would object to the child attending Georgetown University. Moreover, the court found that the defendant could have expected the plaintiff “to be proud of [the child’s] academic accomplishments and supportive of her choices,” both because he is highly educated and because the child chose a Catholic education in line with the plaintiff’s religious beliefs. The court further found that the plaintiff did not raise any objection to the defendant and that the defendant did not prevent him from participating in the child’s college selection. Rather, the court found that the plaintiff “chose to remain silent” and “removed himself from the process,” thereby violating the statutory duty to participate in the college selection and preventing the defendant from availing herself of court intervention to resolve any hypothetical dispute.

The court stated that it had “consider[ed] all relevant circumstances, including, but not limited to, those enumerated in . . . § 46b-56c (c),” and was “particularly mindful of the parties’ debts and the assets and resources available to each of them.” On the basis of these findings, the court granted the defendant’s motion for order and ordered the plaintiff to pay “50 percent of [the child’s] allowable college expenses for her last three semesters at Georgetown University, net of the scholarships and other financial aid she receives, up to the statutory limit set forth in . . . § 46b-56c (g).”6 Additionally, the court 6 The court also adjudicated the defendant’s request for enforcement of prior court orders. The court found: “The parties entered a stipulation on April 11, 2017, requiring each to contribute $3000 toward the purchase of an automobile for the use of their minor children . . . . Specifically, the stipulation provided, ‘The parties shall share 50/50 in the purchase of a motor vehicle at $6000. Until the youngest child graduates high school, the vehicle shall be placed in the name of [the defendant], the parties shall share 50/50 all costs related to the motor vehicle except gas, which shall be paid by [the defendant].’ . . . The stipulation was approved and adopted as an order of the court, Emons, J. . . .

“In an October 19, 2017 decision, the court, Klatt, J., found [the plaintiff] in contempt of court for his failure to make the payments as ordered the plaintiff to cooperate in any financial aid or loan applications for the child. This appeal followed.7

I

The plaintiff’s first claim on appeal is that the court violated his right to due process by “denying oral argument on his motion to dismiss (recharacterized as an objection) and proceeding to the [educational support order] hearing.” The defendant responds that the court “did not deny the plaintiff any due process rights when, after argument, it concluded that it had subject matter jurisdiction to adjudicate the defendant’s motion.” We agree with the defendant.

We begin by setting forth the following applicable standard of review and legal principles. Because the plaintiff’s claim requires us to interpret his motion, our review is plenary. See Swain v. Swain, 213 Conn. App. 411, 418, 277 A.3d 895 (2022) (applying plenary review ordered by Judge Emons. The October 19, 2017 judgment of contempt was subsequently affirmed. . . .

“Neither the stipulation, Judge Emons’ order approving and adopting the stipulation, nor Judge Klatt’s order finding [the plaintiff] in contempt specif[ies] the time by which [the plaintiff] was to make the payments ordered. [The plaintiff] seized upon that omission to avoid his court-ordered obligations. [The defendant’s] motion asks the court to determine a date by which [the plaintiff] must comply with Judge Emons’ order.” (Citations omitted; footnotes omitted.) Noting its authority to issue postjudgment orders effectuating the judgment, the court ordered the plaintiff to pay the defendant “the $3000 ordered by Judge Emons—as well as the $80 for the vehicle’s registration, $360 for his share of the vehicle’s expenses plus the attorney’s fees ordered by Judge Klatt—within thirty days of this order.” As explained hereinafter, we do not address this order on appeal. See footnote 17 of this opinion.

7 On April 16, 2025, the plaintiff moved for an articulation of the legal and factual bases for the court’s decision. See Practice Book § 66-5. On April 30, 2025, the court denied the motion for articulation, stating that the “factual and legal bas[es] of the court’s decision are clearly set forth in its memorandum of decision.” On May 15, 2025, the plaintiff filed a motion for review with this court. This court granted review but denied the relief requested.

The plaintiff subsequently filed a motion to strike portions of the defendant’s appellate brief. In an order dated December 18, 2025, this court denied the motion “without prejudice to the plaintiff including these arguments in his reply brief.”

when interpreting motion). “[A] motion is to be decided on the basis of the substance of the relief sought rather than on the form or the label affixed to the motion. . . . It is the substance of a motion, therefore, that governs its outcome, rather than how it is characterized in the title given to it by the movant.” (Internal quotation marks omitted.) Young v. Bridgeport, 135 Conn. App. 699, 705, 42 A.3d 514 (2012); see also Cocchia v. Testa, 206 Conn. App. 634, 643, 261 A.3d 90 (2021) (“[i]n certain circumstances, this court previously has looked beyond the label of a motion to reclassify it when its substance did not reflect the label applied by the moving party” (internal quotation marks omitted)).

In the present case, it is plain from the content and substance of the plaintiff’s motion that his position was that no educational support order should enter because the defendant had failed to comply with the statutory requirements. Although the plaintiff asked the court to “dismiss” the defendant’s motion,8 he expressly recognized in his motion that “the court retains jurisdiction to enter a postsecondary education[al] support order . . . .” His primary argument was that the statutory prerequisites had not been satisfied. Specifically, in his prayer for relief, the plaintiff requested that the court dismiss the motion on the basis that the defendant had “fail[ed] to abide by statutory requirements.” Moreover, he asserted in the motion that the defendant had “not presented to the court any evidence with her motion to support any claim” that the parties had participated in a discussion regarding the child’s college selection. (Emphasis omitted.)

A motion to dismiss is not the proper procedural vehicle to assert a challenge to the defendant’s satisfaction of the statutory criteria for entry of an educational support order. See McKinnon v. Gardner, 238 Conn. App. 694, 709, 357 A.3d 1105 (2026) (“In this state, a motion to 8 Practice Book § 10-30 (a) provides that “[a] motion to dismiss shall be used to assert: (1) lack of jurisdiction over the subject matter; (2) lack of jurisdiction over the person; (3) insufficiency of process; and (4) insufficiency of service of process.”

dismiss properly attacks the jurisdiction of the court, essentially asserting that the plaintiff cannot as a matter of law and fact state a cause of action that should be heard by the court. . . . A motion to dismiss tests, inter alia, whether, on the face of the record, the court is without jurisdiction.” (Internal quotation marks omitted.)); see also Festa v. Watertown Police Dept., 239 Conn. App. 623, 633, ___ A.3d ___ (2026) (motion to dismiss is not proper procedural vehicle to raise special defenses). Accordingly, we conclude that the court properly determined that the inaptly titled “motion to dismiss” was, in effect, an objection to the defendant’s motion for order.

Finally, we note that the plaintiff was not denied an opportunity to be heard.9 At the hearing on November 19, 2024, the court permitted both parties to express their positions on whether the plaintiff’s motion implicated the court’s jurisdiction. After the court determined that the motion did not implicate jurisdiction and stated its intention to proceed with the hearing on the defendant ’s motion, the plaintiff again addressed the court and directed the court’s attention to authority that he contended supported his position. The plaintiff had an exchange with the court before the court reiterated that it had made a ruling and stated that it would proceed with the hearing. The plaintiff did not indicate that he sought additional argument but, rather, told the court that he would “appeal that ruling immediately.” At the conclusion of the hearing, the plaintiff inquired of the court as to the status of his motion, asking: “Are we going to hear that one or did we quickly hear that one and you overruled it, denied?” The court responded that it had overruled it, and the plaintiff responded, “Okay.” The plaintiff did not alert the court to his position, expressed 9 See, e.g., Surgent v. Surgent, 234 Conn. App. 696, 712–13, 344 A.3d 926 (2025) (“[i]t is a fundamental tenet of due process of law as guaranteed by the fourteenth amendment to the United States constitution and article first, § 10, of the Connecticut constitution that persons whose . . . rights will be affected by a court’s decision are entitled to be heard at a meaningful time and in a meaningful manner”).

in his posthearing briefing and now on appeal, that he did not receive sufficient argument on his motion.

We briefly note that any contention by the plaintiff that he was surprised and, thus, unprepared for the hearing on the motion for an educational support order, as asserted in the facts section of his principal appellate brief and his reply brief, is belied by the record. The parties appeared before the court, Egan, J., on April 25, 2024, at which time the court scheduled a hearing on the motion for an educational support order. The court explained to the plaintiff that “[t]he motion to dismiss . . . it’s not a jurisdictional issue; it’s actually on the merits of the educational support order. And what you’re arguing, sir, is the criteria of the statute. I think you’re going to have to have testimony and a full hearing . . . .”

In sum, because the plaintiff’s motion challenged the defendant’s fulfilment of the statutory prerequisites for the entry of an educational support order, it was, in substance, an objection to the defendant’s motion, and the court properly overruled it. The plaintiff’s claim that he was denied due process, therefore, is unavailing.

II

The plaintiff next claims that the court improperly issued the educational support order because, in doing so, it failed to comply with § 46b-56c. The plaintiff raises several arguments in support of his claim, including that the court failed to consider the circumstances enumerated in the statute and made clearly erroneous factual findings. The defendant responds that the court “properly applied the facts to the statute, and it cannot be said that the trial court abused its discretion in its financial order.” We agree with the defendant.

We begin by setting forth our standard of review and relevant legal principles. “To the extent that the plaintiff’s claim challenges the court’s construction and application of § 46b-56c, our review is plenary.” Buehler v. Buehler, 211 Conn. App. 357, 368, 272 A.3d 736, cert. denied, 343 Conn. 917, 274 A.3d 869 (2022). To the extent that his claim challenges the court’s factual findings underlying its order, we review such challenges pursuant to the clearly erroneous standard. “The trial court’s findings are binding upon this court unless they are clearly erroneous in light of the evidence and the pleadings in the record as a whole. . . . A finding of fact is clearly 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.” (Internal quotation marks omitted .) Id.

Finally, “[u]nder § 46b-56c, whether an educational support order is warranted in a particular case is vested to the sound discretion of the trial court.” Kleinman v. Chapnick, 131 Conn. App. 812, 819, 30 A.3d 3 (2011). “In fashioning its financial orders . . . the court has broad discretion, and [j]udicial review of a trial court’s exercise of [this] broad discretion . . . is limited to the questions of whether the . . . court correctly applied the law and could reasonably have concluded as it did. . . . In making those determinations, we allow every reasonable presumption . . . in favor of the correctness of [the trial court’s] action. . . . That standard of review reflects the sound policy that the trial court has the unique opportunity to view the parties and their testimony, and is therefore in the best position to assess all of the circumstances surrounding a dissolution action, including such factors as the demeanor and the attitude of the parties.” (Internal quotation marks omitted.) Lederle v. Spivey, 113 Conn. App. 177, 193–94, 965 A.2d 621, cert. denied, 291 Conn. 916, 970 A.2d 728 (2009).

Educational support orders are governed by § 46b- 56c, which provides in relevant part: “(a) For purposes of this section, an educational support order is an order entered by a court requiring a parent to provide support for a child or children to attend for up to a total of four full academic years an institution of higher education or a private career school for the purpose of attaining a bachelor’s or other undergraduate degree, or other appropriate vocational instruction. An educational support order may be entered with respect to any child who has not attained twenty-three years of age and shall terminate not later than the date on which the child attains twenty-three years of age. . . .

“(c) The court may not enter an educational support order pursuant to this section unless the court finds as a matter of fact that it is more likely than not that the parents would have provided support to the child for higher education or private career school if the family were intact. After making such finding, the court, in determining whether to enter an educational support order, shall consider all relevant circumstances, including: (1) The parents’ income, assets and other obligations, including obligations to other dependents; (2) the child’s need for support to attend an institution of higher education or private career school considering the child’s assets and the child’s ability to earn income; (3) the availability of financial aid from other sources, including grants and loans; (4) the reasonableness of the higher education to be funded considering the child’s academic record and the financial resources available; (5) the child’s preparation for, aptitude for and commitment to higher education; and (6) evidence, if any, of the institution of higher education or private career school the child would attend. . . .

“(e) At the appropriate time, both parents shall participate in, and agree upon, the decision as to which institution of higher education or private career school the child will attend. The court may make an order resolving the matter if the parents fail to reach an agreement.

“(f) To qualify for payments due under an educational support order, the child must (1) enroll in an accredited institution of higher education or private career school, as defined in section 10a-22a, (2) actively pursue a course of study commensurate with the child’s vocational goals that constitutes at least one-half the course load determined by that institution or school to constitute full-time enrollment, (3) maintain good academic standing in accordance with the rules of the institution or school, and (4) make available all academic records to both parents during the term of the order. The order shall be suspended after any academic period during which the child fails to comply with these conditions.

“(g) The educational support order may include support for any necessary educational expense, including room, board, dues, tuition, fees, registration and application costs, but such expenses shall not be more than the amount charged by The University of Connecticut for a full-time in-state student at the time the child for whom educational support is being ordered matriculates, except this limit may be exceeded by agreement of the parents. An educational support order may also include the cost of books and medical insurance for such child. . . .”

In the present case, the court expressly found, on the basis of the parties’ separation agreement, that they would have provided postsecondary educational support to the child if the family were intact. The plaintiff does not challenge this threshold finding on appeal.

The plaintiff instead makes what the defendant aptly describes as a “ ‘shotgun’ attack on the trial court’s application of . . . § 46b-56c.” As our Supreme Court previously has observed, “such wholesale attacks rarely produce results, tend to cloud the real issues, and in themselves cast doubts on the appellants’ claims.” (Internal quotation marks omitted.) Standard Petroleum Co. v. Faugno Acquisition, LLC, 330 Conn. 40, 52, 191 A.3d 147 (2018). Nonetheless, we have gleaned the following arguments from the plaintiff’s appellate briefs, and we address each in turn.10 We first address the plaintiff’s contention that the court “misattributed fault to the plaintiff for not 10 Two of the plaintiff’s arguments contained within this claim are inadequately briefed. “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. . . . Analysis, rather than mere abstract assertion, is required in order to avoid abandoning an issue knowing the actions of the defendant, in opposition [to] the defendant’s own testimony acknowledging her awareness of the plaintiff’s prior objections . . . .” (Citation omitted.) We construe this contention as challenging the court’s factual findings underlying its determination that the plaintiff had violated his statutory duty to participate in the child’s college selection, which violation the court found “naturally made it impossible for the parties to reach an agreement about [the child’s] college choice.” (Internal quotation marks omitted.)

As noted previously in this opinion, the court made extensive factual findings regarding the parties’ participation in the college selection decision. The court found: “[The plaintiff] attempts to place the blame for the parties’ failure to participate in and agree upon the college [the child] would attend on [the defendant]. That effort is chimerical. [The defendant] had no reason to 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.” (Internal quotation marks omitted.) C. B. v. S. B., 211 Conn. App. 628, 630, 273 A.3d 271 (2022).

First, the plaintiff contends in one sentence of his principal appellate brief that the educational support order is invalid in that the court “failed to include and consider all aspects of § 46b-56c . . . .” We address in this opinion the plaintiff’s contention that the court’s order is ambiguous. To the extent that the plaintiff seeks to argue separately that the educational support order is invalid because it does not contain certain provisions, such a contention is inadequately briefed. See Martin v. Olson, 226 Conn. App. 392, 394–95 n.1, 318 A.3d 1067 (plaintiff’s devotion of only one sentence to argument rendered it inadequately briefed), cert. denied, 350 Conn. 902, 322 A.3d 1059 (2024).

Second, in one brief paragraph, the plaintiff claims that the court “erred by not canvassing and determining the child’s assets, access to loans, and her ability to earn income to pay towards her education.” The plaintiff has not provided any support for the proposition that the trial court was required to conduct a canvass regarding the child’s income. See C. B. v. S. B., supra, 211 Conn. App. 630–31 (brief containing almost no citation to applicable legal authorities was inadequate). Accordingly, we conclude that these two arguments are inadequately briefed, and we decline to review them.

believe [the plaintiff] would object to [the child] attending Georgetown University. She had many reasons to expect him to be proud of [the child’s] academic accomplishments and supportive of her choices, particularly because he is highly educated himself. Moreover, he is a devout Catholic, and Georgetown University is a well respected institution of higher education run by an order of Roman Catholic priests and brothers.

“[The defendant] would have known of [the plaintiff’s] objections only if he had alerted her to them, in which case she could have sought the court’s intervention. He did not do so. Instead, he chose to remain silent, thereby denying [the defendant] the opportunity to have the court weigh in on the issue. . . .

“Although [the plaintiff] may have raised some objections to [the child’s] choice of college with [the child], he did not raise those objections with [the defendant]. The statute at issue does not require the parents to consult with the child, but with each other. The participation and agreement required by the statute is directed at the parents.

“The court rejects [the plaintiff’s] argument that [the defendant] failed to participate [in] and agree on [the child’s] college choice in violation of her obligation under § 46b-56c (e). [The defendant] did not prevent [the plaintiff] from participating in [the child’s] college selection. By remaining silent about his objection to [the child’s] choice, [the plaintiff] removed himself from the process. [The plaintiff] violated his statutory duty to participate in the decision about which institution of higher education [the child] would attend. That violation naturally made it impossible for the parties to reach an agreement about [the child’s] college choice. . . . Under these circumstances, § 46b-56c (e) did not require [the defendant] to presume a disagreement existed about [the child’s] college choice and to seek an order resolving a hypothetical dispute prior to seeking a support order. . . . At a minimum, [the plaintiff] had an obligation to apprise [the defendant] of any objections he had in order to afford her the opportunity to seek the court’s intervention.” (Citations omitted; internal quotation marks omitted.)

The court’s factual findings are supported by the record. The defendant testified that the child was the valedictorian of her high school class and applied to various colleges. The defendant testified that she believed that the child was communicating with the plaintiff relative to her college selection process. The defendant testified that the plaintiff never objected, nor could she think of any reasons why the plaintiff would object, to the child’s selection of Georgetown University. The defendant testified that she “was under the impression that [he] had no objection, therefore, [he was] in agreement with [the child’s] decision.”11 The defendant additionally testified that it was extremely important to the plaintiff to raise his children in the Catholic faith and that Georgetown University is a Catholic institution.

The plaintiff testified that he believed that the child planned to attend college, but he could not recall his discussions with her about her desire to attend college. He testified that he was not sure whether he had asked the child directly as to which schools she had applied, but he recalled having a handful of conversations with her, telling her that he did not have money to pay for an expensive college and suggesting that she attend a state school. The plaintiff testified that he “had no position,”12 11 Specifically, the defendant testified: “[C]onsidering the . . . belligerent relationship that [the plaintiff] and I have, we were not able to participate together in the discussion, but we each individually participated in [it]. It was my impression that [the plaintiff] participated in the discussion with [the child] just as I did with her. I did not hear anything otherwise from [him] that [he was] in disagreement with [the child’s] decision.”

12 The following colloquy transpired between the defendant’s counsel and the plaintiff:

“Q. When [the child] advised you that she had selected Georgetown, did you reach out to [the defendant] and say you objected?

“A. No, because I have no position. “Q. That’s not my question. “A. It was never given a choice to me.

when the child advised him that she had selected Georgetown University. In addition to the parties’ testimony, the court had before it documentary evidence, to which the plaintiff did not object, in the form of an email sent from the child to the plaintiff in April 2021. In the email, the child wrote that she had decided to commit to Georgetown University and requested the plaintiff’s tax return and W-2 form so that she could upload it through the university’s portal to obtain financial aid.

The trial court’s findings that the plaintiff remained silent about his objection to the child’s college selection and thereby removed himself from the process are amply supported by the evidence, and the plaintiff does not identify any evidence suggesting that he attempted to participate in the child’s college selection process. Accordingly, we conclude that the court’s findings are not clearly erroneous because they are supported by the evidence and, on the basis of the record, we are not left with a definite and firm conviction that a mistake has been committed.

Our conclusion finds support in this court’s decision in Buehler v. Buehler, supra, 211 Conn. App. 357. In Buehler, this court affirmed an educational support order after rejecting the plaintiff’s arguments that the court had misconstrued and misapplied what is now § 46b-56c (e). Id., 373–74. Specifically, this court noted the trial court’s findings that the plaintiff had refused to participate in, and had excluded himself entirely from, his child’s college selection process and explained that such failure “naturally made it impossible for the parties “Q. . . . When [the child] told you she was going to go to Georgetown, did you reach out to [the defendant] and say you objected? “A. I did not. “Q. Okay. Did you send a message to me . . . I don’t agree?

***

“Q. Right? I don’t agree. Did you ever do that? “A. No. “Q. Why? “A. Because it was already done, I had no say. I had no authority. It was all stripped from me, so it would have made no sense whatsoever.”

to reach an agreement” with respect to the child’s college choice. Id., 373. This court continued: “That is precisely why § 46b-56c [e] requires both parties to participate in a child’s college selection process. Without mutual participation , there can be no agreement. We do not construe the statute to permit a party to evade responsibility for contributing to a child’s education by engaging in acts or omissions that violate his statutory obligation.” Id. The court further stated that, “by refusing to participate , the plaintiff gave the defendant no indication that he would disagree with [the child’s] decision to attend Quinnipiac University . . . .” Id. Finally, this court concluded that, “[u]nder such circumstances, § 46b-56c [e] did not require the defendant to presume a disagreement existed about [the child’s] college choice and to seek an order resolving a hypothetical dispute prior to seeking a support order.” Id. This court’s reasoning in Buehler is applicable to the present case. Accordingly, the court properly found that the plaintiff had violated his statutory duty to participate in the decision regarding the child’s college selection process.

We next address the plaintiff’s argument that the court failed to consider the statutory factors set forth in § 46b-56c (c). Specifically, the plaintiff contends that he cannot afford to pay 50 percent of the UConn cap, given his debt and limited income. We are not persuaded that the court abused its discretion.

It is important to note at the outset that the court expressly stated that it carefully had considered the circumstances enumerated in § 46b-56c (c) and was “particularly mindful of the parties’ debts and the assets and resources available to each of them.” Cf. Barbour v. Barbour, 156 Conn. App. 383, 397, 113 A.3d 77 (2015) (court failed to comply with § 46b-56c (c), in that it “[did] not state that it had considered any of the factors in the relevant statute” and there was “insufficient evidence in the record to support a conclusion that the court did consider the relevant circumstances”).

The court had before it ample evidence of the parties’ incomes as well as their assets and debts. With respect to the plaintiff’s income, his February 2024 financial affidavit and testimony evidenced weekly gross earnings of approximately $400 from his franchise business,13 $1150 from his military retirement pension, and $343 in disability income. The plaintiff additionally testified that a business interest identified on his financial affidavit with a value of zero dollars “sometimes . . . gets a payment.” On cross-examination, the plaintiff testified that he recently had obtained a wage execution with respect to a judgment in his favor in the amount of $174,000, but that he had not listed it on his financial affidavit because he had yet to receive any funds under that order. The plaintiff also testified that he had business bank accounts holding approximately $25,000, which he had not listed on his financial affidavit because they do not provide personal pay until the end of the year. In addition, the plaintiff testified that he had “been in debt for a long, long time” and had “no money to pay for such expensive schools . . . .” The plaintiff’s financial affidavit identified weekly liability expenses in the amount of $825, which included payments on a $122,680 promissory note held by the plaintiff’s wife.

In light of the court’s express statement that it had considered the relevant factors and affording the court every reasonable presumption in favor of the correctness of its 13 Although the plaintiff originally represented that there had not been any substantial changes since the filing of his financial affidavit in February 2024, he later testified: “I would say the only change would be the Quick Mount TV [franchise] business is doing better. So, there may be a little bit more income that translates down to me at the end of the year after . . . filing the [profit and loss statement] . . . . I am trying to reduce my debts. So, it’s probably a little bit less on the Bank of America, because I’m shifting those debts around, $20,000 here, 20,000 there, when I get the free checks that say do a balance transfer for no cost for a year. I do that so those moneys, I try to balance that. But they’re about the same I would say. Probably in the past year or six months or more, I’ve reduced my debts maybe $10,000. So, that’s that.”

decision; see, e.g., Glenn v. Glenn, 133 Conn. App. 397, 404, 35 A.3d 376 (2012); we are satisfied that the court considered the appropriate statutory factors, including the plaintiff’s “income, assets and other obligations,” as directed by § 46b-56c (c). Having carefully reviewed the record, we conclude that the court’s order was reasonable and, therefore, did not constitute an abuse of discretion.

We next turn to the plaintiff’s contention that the court failed to consider “the availability of financial aid from other sources, including grants and loans . . . .” General Statutes § 46b-56c (c) (3). He contends that “[t]he court did not require, nor did the defendant provide, documentation of the child’s current scholarships, loans, and grants for the final three semesters. Furthermore, the court failed to itemize all required costs for the parties for the last three semesters.” We are not persuaded. There was evidence in the record that, for the child’s freshman and sophomore years, the child owed $18,660 and $17,090, respectively, after application of loans, scholarships, and grants. The defendant testified that the amount owed for the child’s junior year was $52,920 and attributed the difference in the amount owed to a reduction in the total number of household members attending college from four to only one. The defendant introduced into evidence a payment history for the child’s tuition, accessed from Georgetown University’s bursar portal, detailing charges and payments.

The plaintiff testified with respect to the availability of financial aid that “I think [the child] is doing her best to do that, and I am as well.” The plaintiff also testified as to his own communications with Georgetown University ’s financial aid office. Specifically, after the child had reached out to the plaintiff when her financial aid was reduced, the plaintiff contacted the financial aid office and provided additional documentation, which, he represented, resulted in an additional $19,000 in financial aid.

On the basis of the evidence in the record, we conclude that the trial court’s order that the plaintiff pay 50 percent of the allowable expenses for the child’s final three semesters, “net of the scholarships and other financial aid she receives,” up to the UConn cap, did not reflect an abuse of its discretion.14 The plaintiff additionally contends that § 46b-56c (f) (4), which requires that, in order “[t]o qualify for payments due under an educational support order,” the child must “make available all academic records to both parents during the term of the order,” was not satisfied. Specifically, he argues that “[t]he court erred in not requiring, and the defendant failed to provide, itemized tuition statements from the school, including grants, scholarships, and loans.” A review of the plain language of the statute as applied to the facts of this case defeats the plaintiff’s argument. The statute requires the child, in order to qualify for payments due under an order, to make available academic records “during the term of the order.” General Statutes § 46b-56c (f) (4). The statute further provides that “[t]he order shall be suspended after any academic period during which the child fails to comply with these conditions.” General Statutes § 46b- 56c (f). Accordingly, we do not construe this statutory condition to operate as a prerequisite to the entry of an educational support order. Rather, it imposes a duty on the child, during the term of the order, to make available academic records in order to qualify for payments due. Moreover, as noted previously, the plaintiff was in direct communication with the financial aid office, and there is nothing in the record to suggest that any information was withheld from him or otherwise inaccessible to him. Cf. Lenczewski v. Lenczewski, 229 Conn. App. 752, 766 n.8, 328 A.3d 718 (2024) (stating that trial court had 14 We also note that the plaintiff, in his posthearing brief, did not argue that the order should not issue on the basis that the defendant had presented insufficient evidence.

found noncompliance with § 46b-56c (f) (4) where it was undisputed that parent was “denied access to [the child’s] academic records and the parent portal where she could obtain pertinent information” (internal quotation marks omitted)). Thus, the plaintiff’s argument fails.

Finally, in one paragraph of his principal appellate brief, the plaintiff contends that the educational support order is impermissibly vague, in that it fails to specify the amount of the UConn cap, the itemized educational costs, the payee, and the payment due date. We first note that the authority cited by the plaintiff in relation to this claim does not support his position, and we are not persuaded that the statute requires the level of specificity that the plaintiff claims it does. Section 46b-56c (g) requires that the expenses ordered to be paid by a parent “shall not be more than the amount charged by The University of Connecticut for a full-time in-state student at the time the child for whom educational support is being ordered matriculates . . . .” The statute does not require that the order specify that amount.15 See, e.g., Buehler v. Buehler, supra, 211 Conn. App. 366–67 (trial court ordered plaintiff to pay invoice “up to the statutory cap set forth in § 46b-56c [g]” without identifying cap).16 15 We note that the defendant’s counsel questioned the defendant regarding the approximate cost of the University of Connecticut as being $35,000, and the defendant confirmed that she understood that the court could award only up to that approximate amount. The present case is different from Tobet v. Tobet, 119 Conn. App. 63, 986 A.2d 329 (2010), on which the plaintiff relies. In Tobet, this court determined that the trial court’s finding that tuition and board at the University of Connecticut was “roughly $16,000 or $17,000” and, thus, that “neither of the parties is responsible for anything in excess of $16,000”; (internal quotation marks omitted) id., 67; was clearly erroneous because this court’s “review of the transcript reveal[ed] that no evidence as to the cost of the annual tuition and board at the University of Connecticut at Storrs was presented to the court.” Id., 70.

16 See also, e.g., Dennis-Gervais v. Gervais, Docket No. HHD-FA-21-

6143311-S, 2023 WL 7873163, *5 (Conn. Super. April 29, 2023) (“[e]ach party shall pay one-third of each child’s college costs, which are defined as the sum of a child’s room, board, dues, tuition, customary fees, books, registration and application costs, provided that neither party shall be obligated to pay more for any child than one-half of what is required under . . . § 46b-56c [g] (the ‘UConn cap’)”); Noriega v. Noriega, Docket

Additionally, with respect to the plaintiff’s argument that the court failed to identify the payee or the payment date, § 46b-56c (h) provides only that the court “may direct that payments under an educational support order be made (1) to a parent to be forwarded to the institution of higher education or private career school, (2) directly to the institution or school, or (3) otherwise as the court determines to be appropriate.” (Emphasis added.) Thus, we reject the plaintiff’s contention that the court was statutorily required to expressly direct the payment, particularly in the present case in which the child, at the time of the hearing, was nearing completion of the first semester of her senior year.

Finally, although the plaintiff filed a motion for articulation with the trial court with respect to seventeen issues, the motion did not request any clarification regarding those aspects of the trial court’s decision that he now claims are ambiguous. See Pishal v. Pishal, 212 Conn. App. 607, 616, 276 A.3d 434 (2022) (“[i]t is . . . the responsibility of the appellant to move for an articulation or rectification of the record where the trial court has failed to state the basis of [a] decision . . . [or] to clarify the legal basis of a ruling” (internal quotation marks omitted)).

Accordingly, we conclude that the court properly entered its educational support order.

III

We next turn to the plaintiff’s multiple claims, combined into a single section of his principal appellate brief, that the court’s issuance of the educational support order violated his constitutional rights. First, he asserts No. MMX-FA-XX-XXXXXXX-S, 2023 WL 7871546, *6 (Conn. Super. January 4, 2023) (“[i]f the parents’ combined obligation for an academic year shall exceed the amount charged by the University of Connecticut for a full-time in-state student at the time [the child] matriculated at Wesleyan University (the ‘UConn cap’), then the parents’ respective maximum obligations for such academic year shall be reduced pro rata so that their combined obligation equals the UConn cap”).

that the court violated his rights under the federal and state constitutions by “ordering a financial obligation, in part or in whole, based upon the plaintiff’s religion.” Second, the plaintiff contends that the court violated his “constitutional protections by compelling the plaintiff to incur debt beyond his means absent a rational basis and . . . [violated his] equal protection [rights] by creating disparate classes of citizens . . . .” Third, he maintains that “the statute creates a separate class of parents (married versus unmarried) and adult children (those with married parents and those whose parents are unmarried), which is unconstitutional.” We decline to review these claims because the plaintiff failed to adequately brief them.

“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. . . . Analysis , rather than mere abstract assertion, is required in order to avoid abandoning an issue by failure to brief the issue properly. . . . [When] a claim is asserted in the statement of issues but thereafter receives only cursory attention in the brief without substantive discussion or citation of authorities, it is deemed to be abandoned. . . . 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 disorganized. . . . 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.) C. B. v. S. B., 211 Conn. App. 628, 630, 273 A.3d 271 (2022). Our appellate courts previously have explained that, “[a]lthough 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, 321 Conn. 688, 726, 138 A.3d 868 (2016); see also Alterio v. Spak, 237 Conn. App. 84, 92, 349 A.3d 614 (2026).

In the present case, the plaintiff’s briefing of his constitutional claims is sparse, with each of the three claims occupying only one paragraph of his brief. See Alterio v. Spak, supra, 237 Conn. App. 92–93 (declining to review claims when each occupied less than one page of briefing). Moreover, although the plaintiff includes five case citations in support of his constitutional claims, two of those citations are to state cases from other jurisdictions, and all five citations are unaccompanied by any application to the present case. See C. P. v. Riordan, 240 Conn. App. 478, 492, ___ A.3d ___ (2026) (claim was inadequately briefed, as defendant failed to analyze precedent and apply it to her claim).

Having thoroughly reviewed the record and the plaintiff ’s brief, we conclude that we cannot properly address his constitutional claims on appeal because they are inadequately briefed, and, thus, we decline to review them.17 The judgment is affirmed. In this opinion the other judges concurred. 17 The plaintiff raises two additional claims on appeal. He claims that the court failed to enforce the parties’ separation agreement. Additionally , he claims that “[t]he trial court erred by permitting the defendant to revive a stayed 2020 litigation for a $3000 payment (plus $440 in vehicle expenses) by incorporating it into an unrelated” educational support order motion and in awarding the defendant attorney’s fees. See footnote 6 of this opinion. For the same reasons expressed with respect to his constitutional claims, we conclude that these claims are inadequately briefed, and we decline to review them.