## Facts

- In 1996, Gina Karjanis (plaintiff) married Steven Karjanis, Sr. (defendant).
- Before the marriage, Gina worked full time as a nurse and was used to a comfortable standard of living.
- The couple agreed that after having children, Gina would stop working and focus on the home; they later had two children.
- Over time, Steven exercised increasing control over family life and household decision-making, including strict control of finances and routine purchases (e.g., refusing to allow certain household appliances).
- In 2003, after Steven attacked Gina in front of the children, Gina obtained a restraining order and filed for dissolution of the marriage.
- During the case, Steven violated stay-away orders connected to the family residence and pressured Gina to reconcile, including statements that he would make matters difficult if she did not.
- Steven’s parenting time was inconsistent. The children (about five and six) were affected by Steven’s conduct during visits, including calling Gina “the devil” in their presence and ending a visit early when a child could not find shoes quickly, leaving the child upset.
- Steven stated he wanted a relationship with the children but demanded that contact occur on his terms, including seeking access to the children in the family home.
- Gina returned to full-time nursing work and arranged in-home care for the children.
- The trial court received evidence about the parties’ conduct, the children’s needs, and the parties’ financial circumstances to determine dissolution, custody/visitation, and financial orders.

## Issues

1. Whether the marriage should be dissolved on the ground that it had broken down irretrievably.
2. What custody and visitation orders were in the children’s best interests given the history of family violence, coercive conduct, and the father’s behavior during parenting time.
3. How to allocate property and set alimony and child support under Connecticut’s dissolution statutes, including consideration of the causes of the marital breakdown and the economic consequences of the marital roles and conduct.

## Decision

- The court dissolved the marriage after finding an irretrievable breakdown.
- The court awarded the mother primary physical custody and structured the father’s visitation in a limited, regulated manner to protect the children’s welfare in light of the evidence of violence, intimidation, and harmful parental conduct.
- The court entered financial orders, including child support and alimony, and divided marital property equitably but not equally, awarding the wife a larger share based on the statutory factors and the court’s findings about the husband’s conduct and its effects.

## Legal Principles

- A Connecticut court may dissolve a marriage upon finding an irretrievable breakdown with no reasonable prospect of reconciliation.
- Custody and visitation determinations are governed by the children’s best interests; a court may consider family violence, threats, coercive behavior, and the impact of parental conduct on the children’s emotional security.
- A court may impose conditions and limits on visitation when the evidence shows that unrestricted contact would likely harm the children or expose them to ongoing conflict or intimidation.
- Connecticut follows equitable distribution, not automatic equal division; in dividing property and awarding alimony, the court considers statutory factors such as the length of the marriage, the parties’ ages and health, occupations, employability, earning capacities, needs, contributions, and the causes of the breakdown.
- A party’s abusive or controlling conduct may be treated as a cause of the marital breakdown and weighed in financial awards, including unequal property distribution and spousal support.

## Conclusion

In Karjanis v. Karjanis, the Connecticut Superior Court granted a dissolution and fashioned custody, visitation, and financial orders after finding that the husband’s violence and pattern of control drove the marital breakdown and harmed the children’s stability; the court placed the children primarily with the mother, limited and regulated the father’s contact, and ordered support and an unequal but equitable distribution of property consistent with Connecticut’s statutory factors.


Karjanis v. Karjanis, 2005 WL 1274112 (2005)