In Alliance Partners, Inc. v. Oxford Health Plans, Inc., 263 Conn. 191, 819 A.2d 227 (2003), the plaintiff real estate services provider brought an action against the defendant health maintenance organization for money owed in connection with the plaintiff's representation of the defendant when it leased certain real estate. A referee issued a report recommending judgment for the defendant. Id., 193.
The trial court accepted the report and rendered judgment for the defendant. Id. From that judgment, the plaintiff appealed. In denying the appeal, our Supreme Court stated that "it is well settled that an articulation is appropriate where the trial court's decision contains some ambiguity or deficiency reasonably susceptible of clarification. . . . Proper utilization of the motion for articulation serves to dispel any . . . ambiguity by clarifying the factual and legal basis upon which the trial court rendered its decision, thereby sharpening the issues on appeal. . . . The appellant's failure to seek an articulation of the trial court's decision to clarify the aforementioned issues and to preserve them properly for appeal leaves this court without the ability to engage in a meaningful review." Id., 204.