F. S. v. J. S.

Citations

• 223 Conn. App. 763

Syllabus

The defendant appealed from the judgment of the trial court awarding sole legal and physical custody of the parties' minor child, O, to the plaintiff and imposing certain restrictions on his visitation with O. After the plaintiff initiated the underlying marital dissolution action, the parties filed numerous motions with the court, and, given the volume and nature of the motions, the court ordered that neither party could file any additional motions without first requesting leave from the court, with an exception for ex parte emergency requests approved by the guardian ad litem. The parties thereafter entered into an agreement to dissolve their marriage, which indicated that, although they agreed upon the division of their marital property and debt and the issue of alimony, they had been unable to resolve issues related to custody, access and care of O and that those issues should be resolved by the court in subsequent proceedings after completion of a custody evaluation by S, a clinical psychologist. The court subsequently rendered a judgment of dissolution of marriage that incorporated the parties' agreement. S filed her custody evaluation with the court, and the custody hearing was scheduled to commence in March, 2020, but, due to the COVID-19 pan- demic, it did not go forward as scheduled. When the trial ultimately commenced, the court heard testimony from L, a social worker from the Department of Children and Families, over repeated objections by the defendant. L testified that she had investigated an anonymous call made to the department concerning the plaintiff's purported physical removal of O from a baseball game in which he was participating. During L's testimony, a redacted version of the relevant department investigation protocol was admitted into evidence as a full exhibit. L testified that her investigation included, among other things, interviews with O and conversations with G, O's former therapist, and that, as a result of her investigation, the dep