## Facts

- Beverly L. Grimm (wife) and Robert L. Grimm (husband) separated in 1988 and engaged in prolonged, contentious dissolution litigation across multiple filings and withdrawals.
- The wife filed the operative dissolution action in Connecticut in 1997, alleging irretrievable breakdown.
- Trial proceeded over approximately sixteen days in 2002 with extensive testimonial and documentary evidence.
- In 2003, the trial court dissolved the marriage and entered financial orders, including transfer of the husband’s interest in the marital home, lump-sum alimony, and a substantial attorney’s fee award to the wife.
- The husband appealed; the Appellate Court largely affirmed the dissolution judgment and financial orders but reversed the attorney’s fee award.
- The Connecticut Supreme Court granted certification on the husband’s challenges to the financial orders and the wife’s cross-appeal seeking reinstatement of attorney’s fees.

## Issues

1. Whether challenges to the trial court’s dissolution financial orders warranted reversal when the appellant failed to provide an adequate record and adequately brief certain claims.
2. Whether the trial court abused its discretion by awarding attorney’s fees to the wife in the dissolution judgment.

## Decision

- The Supreme Court affirmed the Appellate Court’s judgment upholding the trial court’s financial orders, but on alternate grounds.
- The Court held that appellate review of certain financial-order claims was barred by an inadequate record and, for other claims, by abandonment through inadequate briefing.
- The Court reversed the Appellate Court’s ruling on attorney’s fees and reinstated the trial court’s fee award, concluding it was not an abuse of discretion.

## Legal Principles

- An appellant bears the burden of furnishing an adequate record for appellate review; absent a sufficient record, claimed error will not be reviewed.
- Issues inadequately briefed may be treated as abandoned.
- Financial orders in marital dissolution actions are reviewed for abuse of discretion; trial courts have broad authority to craft equitable orders based on the evidence and statutory factors.
- Attorney’s fee awards in dissolution actions are discretionary and may be based on the parties’ financial circumstances and equitable considerations, including whether a fee award is necessary to preserve the effectiveness of the overall financial scheme; appellate courts should not disturb such awards absent abuse of discretion.

## Conclusion

The Connecticut Supreme Court left the dissolution financial orders intact because the husband did not supply an adequate record and did not properly brief certain challenges, and it restored the trial court’s attorney’s fee award after holding that the trial court acted within its discretion in light of the parties’ circumstances and the overall equities of the case.


Grimm v. Grimm, 276 Conn. 377, 886 A.2d 391 (Conn. 2005)