Pryor v. Pryor
Connecticut General Statutes §52-434a(a) affords judge trial referees the same powers and jurisdiction as judges of the court from which proceedings have been referred to them. The defendant, Edmond Pryor, appealed from a post-dissolution proceeding, claiming, inter alia, that the trial court improperly found him in contempt for failing to pay the fees of the court-appointed guardian ad litem of his minor children, Attorney Jocelyn Hurwitz, for services rendered throughout the contentious litigation leading up to the dissolution of his marriage to the plaintiff, Lynda Pryor. The Appellate Court affirmed the judgment. The lower court never made a finding that the defendant was or was not in contempt for not paying the guardian ad litem's fees. Nor did the court explain the basis for two other challenged orders on motions for a protective order. Absent such an explanation, there was no basis upon which the Appellate Court could conclude that the court abused its discretion. The defendant also claimed that because the judge who heard the motions, the honorable Howard Owens, was a judge trial referee, he lacked the authority to hold the defendant in contempt for violating an order issued by a Superior Court judge. The defendant did not object to Judge Owens' consideration of the motion for contempt or motions for a protective order until he received unfavorable rulings. He did not raise the claim until a hearing on his motion to re-argue the rulings. In summarily denying the motion to re-argue, the court did not address the claim and the defendant did not ask the court to clarify or articulate its decision. Because C.G.S. §52-434a(a) affords judge trial referees the same powers and jurisdiction as judges of the court from which proceedings have been referred to them, the claim that Judge Owens lacked authority to preside over the motion for contempt was found to be without merit.