Majkut v. Majkut

Connecticut Appellate Court·Decided August 4, 2026·No. AC48812, AC48835·Published

Opinion

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************ Majkut v. Majkut

BONNIE M. MAJKUT v. PAUL S. MAJKUT (AC 48812) (AC 48835) Elgo, Seeley and DiPentima, Js.

The parties separately appealed from certain of the trial court’s postjudgment orders, in which the court granted the defendant’s motion for contempt, finding that the plaintiff had violated a nondisparagement clause in the parties’ parenting plan that was incorporated into the dissolution judgment, and made various modifications to the parties’ postdissolution custody and visitation orders regarding their minor children. On appeal, the plaintiff claimed that the nondisparagement clause violated her right to freedom of speech pursuant to the federal and state constitutions, and the defendant claimed, inter alia, that the court erred in granting sole legal custody of the parties’ minor children to the plaintiff. Held:

The plaintiff’s claim that the nondisparagement clause in the parties’ par- enting plan, as incorporated into the judgment of dissolution, constituted an invalid prior restraint on her right to free speech pursuant to the first amendment to the United States constitution and article first, §§ 4 and 5, of the Connecticut constitution was unavailing, as the plaintiff validly waived her free speech rights pursuant to the nondisparagement clause because she was represented by counsel and agreed to be bound by the parenting plan, and the court’s subsequent enforcement of that contractual provision did not violate the plaintiff’s right to free speech pursuant to either the federal or state constitution.

The trial court did not abuse its discretion in awarding the plaintiff sole legal custody of the parties’ minor children, as the defendant had voluntarily relocated to Ukraine, a country that was actively at war, which the court considered to be a material change in circumstances, and the defendant retained the right to be present for various appointments and to access his minor children’s medical, academic and personal records.

The trial court did not abuse its discretion in fashioning its visitation sched- ule order, which granted visitation by agreement of the parties, as the order reflected its broad discretion to fashion flexible and individualized visitation orders, the visitation order on appeal was similar to a prior visitation order that the court entered pursuant to the parties’ separation agreement, and the court’s order was related to scheduling only and did not restrict the defendant’s right to visitation with his minor children or improperly delegate to the plaintiff the authority to suspend the defendant’s right to visitation.

The trial court did not abuse its discretion in awarding the defendant reason- able attorney’s fees for his successful motion for contempt, as the court made specific findings as to the amount of attorney’s fees incurred in relation to Majkut v. Majkut

the motion for contempt and explicitly declined to award the defendant any additional fees, which was within the court’s broad discretion in awarding attorney’s fees.

Argued April 20—officially released August 4, 2026

Procedural History

Action for the dissolution of a marriage, and for other relief, brought to the Superior Court in the judicial district of Tolland and tried to the court, Nascimento, J.; judgment dissolving the marriage and granting cer- tain other relief in accordance with the parties’ separa- tion agreement; thereafter, the court, Carrasquilla, J., granted the plaintiff’s motion to modify the settlement agreement and the defendant’s motion for contempt, and the parties filed separate appeals to this court. Affirmed. Bonnie M. Majkut, self-represented, the appellant in Docket No. AC 48835 and the appellee in Docket No. AC 48812 (plaintiff). Paul S. Majkut, self-represented, the appellant in Docket No. AC 48812 and the appellee in Docket No. AC 48835 (defendant).

Opinion

ELGO, J. In these two related appeals, the plaintiff, Bonnie M. Majkut, and the defendant, Paul S. Majkut, each appeal from the trial court’s May 21, 2025 postjudg- ment orders, in which the court granted the defendant’s motion for contempt and made various modifications to the parties’ postdissolution custody and visitation orders regarding their minor children.1 In Docket No. AC 48835, the plaintiff claims that the court improperly found her in contempt for violating a nondisparagement clause in the parties’ parenting plan that was incorpo- rated into the dissolution judgment. Specifically, the 1 The plaintiff’s appeal is docketed before this court as AC 48835, and the defendant’s appeal is docketed as AC 48812. We address the claims Majkut v. Majkut

plaintiff claims that the nondisparagement clause (1) violated her right to freedom of speech, pursuant to the first amendment to the constitution of the United States, because it constituted an impermissible prior restraint on speech and (2) violated her right to freedom of speech, pursuant to article first, §§ 4 and 5, of the constitution of Connecticut, because it constituted an impermissible prior restraint on speech.2 The plaintiff also challenges the award of attorney’s fees to the defen- dant.3 In Docket No. AC 48812, the defendant claims that (1) the court erred in granting sole legal custody of the parties’ minor children to the plaintiff, (2) the visitation schedule ordered by the court constituted an impermissible delegation of judicial decision-making, of these related appeals together. See, e.g., In re Amani O., 221 Conn. App. 59, 62 n.1, 301 A.3d 565 (2023). 2 To the extent that the plaintiff argues for the first time on appeal that she did not agree to the nondisparagement clause voluntarily and intelligently, that defense was not raised before the trial court. More- over, there is no dispute that the plaintiff was represented by counsel during all applicable times in the divorce proceedings. We therefore decline to review this unpreserved claim raised for the first time on appeal. See, e.g., Martin v. Todd Arthurs Co., 225 Conn. App. 844, 854–55, 317 A.3d 98 (2024). The plaintiff also claims that the court erred in holding her in con- tempt of the nondisparagement clause because all of the statements she had made in violation of that clause were true. Truth as a defense is applicable to defamation, libel or slander actions, not to the defendant’s motion for contempt in the present case. See, e.g., Mercer v. Cosley, 110 Conn. App. 283, 301, 955 A.2d 550

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