Millbrook Owners Assn., Inc. v. Hamilton Standard
In Millbrook Owners Assn., Inc. v. Hamilton Standard, 257 Conn. 1, 17-18, 776 A.2d 1115 (2001) the Court stated: "For a trial court's order of sanctions for violation of a discovery order to withstand scrutiny, three requirements must be met.
"First, the order to be complied with must be reasonably clear. In this connection, however, we also state that even an order that does not meet this standard may form the basis of a sanction if the record establishes that, notwithstanding the lack of such clarity, the party sanctioned in fact understood the trial court's intended meaning. This requirement poses a legal question that we will review de novo.
"Second, the record must establish that the order was in fact violated. This requirement posses a question of fact that we will review using a clearly erroneous standard of review.
"Third, the sanction imposed must be proportional to the violation. This requirement poses a question of the discretion of the trial court that we will review for abuse of that discretion." Id., 17-18.