Hamilton v. Hamilton

Summary

The court held that a postjudgment motion to modify custody is a short calendar matter governed by Practice Book § 11-19, so the plaintiff waived any timeliness challenge by failing to seek reassignment within the prescribed period. The court declined to review the claim concerning two unresolved contempt motions because the plaintiff did not seek an articulation or ask the trial court to rule. It reversed the custody determination because the trial court improperly and harmfully took judicial notice, without notice or an opportunity to be heard, of a disputed fact from an unrelated custody proceeding.