Cohen v. Cohen
In Cohen v. Cohen, 41 Conn. App. 163, 674 A.2d 869 (1996), an agreement of the parties that covered child support of their two minor children was incorporated into the judgment of dissolution.
No appeal was taken from the judgment of dissolution. There is no indication that the case involved a nonmodifiable provision for child support.
Almost one year later, the plaintiff sought to open the judgment to have retroactive child support orders issued in accordance with the guidelines.
The trial court denied the plaintiff's motion, and he appealed. Id., 164.
On appeal, the plaintiff in Cohen claimed that although the parties privately had agreed to the amount of child support the plaintiff was required to pay, the trial court improperly failed to consider or make reference to the child support guidelines as required by 46b-215b (a). Id., 165.
The Court declined to review the plaintiff's claim and affirmed the judgment of the trial court because the plaintiff failed to provide an adequate record for appellate review.