Villao v. Paz

Connecticut Appellate Court·Decided September 8, 2026·No. AC48574·Published

Opinion

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JONATHAN I. VILLAO v. GRISELL V. PAZ (AC 48574)

Suarez, Seeley and Westbrook, Js.

Syllabus

The defendant appealed from the trial court’s judgment dissolving her marriage to the plaintiff and granting certain other relief. The defendant claimed, inter alia, that the court abused its discretion in calculating its basic child support award. Held:

The trial court’s child support orders constituted an abuse of its discretion, as the court’s finding as to the presumptive child support award was not supported by the record, and, to the extent that the court indicated that it relied on the parties’ incomes as listed in the defendant’s child support guidelines worksheet in determining the presumptive child support amount, that determination was clearly erroneous as it was not based on the plaintiff’s net income at the time the court issued its decision.

Argued May 18—officially released September 8, 2026

Procedural History

Action for the dissolution of a marriage, and for other relief, brought to the Superior Court in the judicial district of Stamford-Norwalk, where the defendant filed a cross complaint; thereafter, the case was tried to the court, Cirello, J.; judgment dissolving the marriage and granting certain other relief, from which the defendant appealed to this court. Reversed in part; new trial. Anthony L. Cenatiempo, with whom, on the brief, was Norman A. Roberts II, for the appellant (defendant).

Alexandra G. Duffy, with whom, on the brief, was Ingemar Heredia, for the appellee (plaintiff).

Opinion

SUAREZ, J. The defendant, Grisell V. Paz, appeals from the judgment of the trial court dissolving her marriage to the plaintiff, Jonathan I. Villao. On appeal, the defendant claims that the court abused its discretion in (1) calculating its basic child support award, (2) determining its alimony award, (3) ordering the defendant to pay attorney’s fees, and (4) fashioning its property distribution orders.1 We conclude that the court abused its discretion in determining its child support orders and, accordingly, reverse in part the judgment of the trial court and remand the case for a new trial on all financial orders.2 The following procedural history and facts, as found by the court, are relevant to this appeal. The parties were married on August 30, 2018, in Stamford. The parties 1 We note that, in her statement of issues, the defendant characterized the claims raised on appeal as follows: “(1) The trial court’s child support order is erroneous requiring reversal and remand on all financial issues . . . . (2) The trial court’s alimony order is erroneous requiring reversal and remand on all financial issues . . . . (3) The trial court erred when it ordered the defendant to pay counsel fees to the plaintiff . . . . [And] (4) [t]he trial court’s property distribution orders are [harmful], erroneous and require reversal and remand on all financial issues.” We have reframed the claims in this appeal for clarity and to more accurately reflect the arguments set forth in the body of the defendant’s brief. See Doe v. Quinnipiac University, 218 Conn. App. 170, 173 n.4, 291 A.3d 153 (2023).

2 Because we conclude that the court erred with respect to its child support orders, we need not reach the defendant’s claims related to the court’s alimony orders, division of property orders, or award of attorney’s fees. See, e.g., Tuckman v. Tuckman, 308 Conn. 194, 215, 61 A.3d 449 (2013) (concluding that, because it was uncertain whether trial court’s financial awards would remain intact after reconsidering child support orders and defendant’s available income, entirety of mosaic must be refashioned); Renstrup v. Renstrup, 217 Conn. App. 252, 255 n.2, 287 A.3d 1095 (in light of conclusion that trial court erred with respect to child support and alimony orders, this court declined to reach claims related to trial court’s division of property orders), cert. denied, 346 Conn. 915, 290 A.3d 374 (2023).

We note that the defendant’s alimony claim on appeal is that the court improperly awarded future alimony without making an express finding of earning capacity. The court did not make any express findings concerning the basis for its alimony award, including the parties’ available net income or future earning capacity. Although we decline to address this claim, we note that, on remand, an alimony award, if any, must be supported by the evidence and may not be merely speculative . It is well established that “when a trial court has based a financial award . . . on a party’s earning capacity, the court must determine the specific dollar amount of the party’s earning capacity. . . . Awards of alimony and support that are based on earning capacity must be supported by evidence that includes specific amounts of past earnings, or of vocational evidence as to the typical salary of the imputed party’s occupation considering that party’s ability and experience.” (Citation have two minor children issue of the marriage. On January 9, 2024, the plaintiff commenced this dissolution action. In his amended complaint dated April 3, 2024, the plaintiff sought a dissolution of the parties’ marriage , alimony, and an equitable distribution of assets.3 On April 30, 2024, the defendant filed an answer and a cross complaint in which she claimed that the parties had entered into a prenuptial agreement and sought enforcement of the agreement. On December 17, 2024, the plaintiff filed an amended motion to set aside the prenuptial agreement.

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