mosaic doctrine in Connecticut

2011“The rendering of a judgment in a complicated dissolution case is a carefully crafted mosaic, each element of which may be dependent on the other.” Ehrenkranz v. Ehrenkranz, 2 Conn. App. 416, 424 , 479 A.2d 826 (1984). “[0]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideration of all financial orders even though the review process might reveal a flaw only in the alimony, property distribution or child support awards.” Casey v. Casey, 82 Conn. App. 378 , 389 n.9, 844 A.2d 250 (2004).

2011“The rendering of a judgment in a complicated dissolution case is a carefully crafted mosaic, each element of which may be dependent on the other.” Ehrenkranz v. Ehrenkranz, 2 Conn. App. 416, 424 , 479 A.2d 826 (1984). “[0]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideration of all financial orders even though the review process might reveal a flaw only in the alimony, property distribution or child support awards.” Casey v. Casey, 82 Conn. App. 378 , 389 n.9, 844 A.2d 250 (2004).

2024Under the mosaic doctrine, financial orders should not be viewed as a collection of single disconnected occur- rences, but rather as a seamless collection of interde- pendent elements. . . . [W]e will not disturb a trial court’s orders in domestic relations cases unless the court has abused its discretion or it is found that it could not reasonably conclude as it did, based on the facts presented.’’ (Citations omitted; emphasis in original; internal quotation marks omitted.) Pencheva-Hasse v. Hasse, 221 Conn. App. 113 , 129-30, 300 A.3d 1175 (2023). ‘‘[W]hen a trial court states in its memoran

2024Under the mosaic doctrine, financial orders should not be viewed as a collection of single disconnected occur- rences, but rather as a seamless collection of interde- pendent elements. . . . [W]e will not disturb a trial court’s orders in domestic relations cases unless the court has abused its discretion or it is found that it could not reasonably conclude as it did, based on the facts presented.’’ (Citations omitted; emphasis in original; internal quotation marks omitted.) Pencheva-Hasse v. Hasse, 221 Conn. App. 113 , 129-30, 300 A.3d 1175 (2023). ‘‘[W]hen a trial court states in its memoran

2024Under the mosaic doctrine, financial orders should not be viewed as a collection of single disconnected occur- rences, but rather as a seamless collection of interde- pendent elements. . . . [W]e will not disturb a trial court’s orders in domestic relations cases unless the court has abused its discretion or it is found that it could not reasonably conclude as it did, based on the facts presented.’’ (Citations omitted; emphasis omitted; internal quotation marks omitted.) Pencheva-Hasse v. 0 Conn. App. 1 ,0 11 Briggs v. Briggs Hasse, 221 Conn. App. 113 , 129-30, 300 A.3d 1175 (2023). ‘‘[W]hen a

2024Under the mosaic doctrine, financial orders should not be viewed as a collection of single disconnected occur- rences, but rather as a seamless collection of interde- pendent elements. . . . [W]e will not disturb a trial court’s orders in domestic relations cases unless the court has abused its discretion or it is found that it could not reasonably conclude as it did, based on the facts presented.’’ (Citations omitted; emphasis in original; internal quotation marks omitted.) Pencheva-Hasse v. Hasse, 221 Conn. App. 113 , 129-30, 300 A.3d 1175 (2023). ‘‘[W]hen a trial court states in its memoran

2023Because the court’s support orders, particularly its spousal support or alimony order, are informed by and reflective of the parties’ incomes and assets, as affected by the court’s other financial orders, the entirety of the mosaic must be refashioned whenever there is error in the entering of any such interde- pendent order.’’ (Citation omitted.) O’Brien v. O’Brien, 138 Conn. App. 544, 555 , 53 A.3d 1039 (2012), cert. denied, 308 Conn. 937 , 66 A.3d 500 (2013). ‘‘[O]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideratio

2023Because the court’s support orders, particularly its spousal support or alimony order, are informed by and reflective of the parties’ incomes and assets, as affected by the court’s other financial orders, the entirety of the mosaic must be refashioned whenever there is error in the entering of any such interde- pendent order.’’ (Citation omitted.) O’Brien v. O’Brien, 138 Conn. App. 544, 555 , 53 A.3d 1039 (2012), cert. denied, 308 Conn. 937 , 66 A.3d 500 (2013). ‘‘[O]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideratio

2023Because the court’s support orders, particularly its spousal support or alimony order, are informed by and reflective of the parties’ incomes and assets, as affected by the court’s other financial orders, the entirety of the mosaic must be refashioned whenever there is error in the entering of any such interde- pendent order.’’ (Citation omitted.) O’Brien v. O’Brien, 138 Conn. App. 544, 555 , 53 A.3d 1039 (2012), cert. denied, 308 Conn. 937 , 66 A.3d 500 (2013). ‘‘[O]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideratio

2023Because the court’s support orders, particularly its spousal support or alimony order, are informed by and reflective of the parties’ incomes and assets, as affected by the court’s other financial orders, the entirety of the mosaic must be refashioned whenever there is error in the entering of any such interde- pendent order.’’ (Citation omitted.) O’Brien v. O’Brien, 138 Conn. App. 544, 555 , 53 A.3d 1039 (2012), cert. denied, 308 Conn. 937 , 66 A.3d 500 (2013). ‘‘[O]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideratio

2018Generally, we will not overturn a trial court's division of marital property unless it misapplies, overlooks, or gives a wrong or improper effect to any test or consideration which it was [its] duty to regard." (Internal quotation marks omitted.) Greco v. Greco , 275 Conn. 348 , 355-56, 880 A.2d 872 (2005).

2018Generally, we will not overturn a trial court's division of marital property unless it misapplies, overlooks, or gives a wrong or improper effect to any test or consideration which it was [its] duty to regard." (Internal quotation marks omitted.) Greco v. Greco , 275 Conn. 348 , 355-56, 880 A.2d 872 (2005).

2016Consistent with that approach, our courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideration of all financial orders even though the review process might reveal a flaw only in the alimony, property distribution or child support awards." (Internal quotation marks omitted.) Valentine v. Valentine , 149 Conn.App. 799 , 803, 90 A.3d 300 (2014).

2016Consistent with that approach, our courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideration of all financial orders even though the review process might reveal a flaw only in the alimony, property distribution or child support awards." (Internal quotation marks omitted.) Valentine v. Valentine , 149 Conn.App. 799 , 803, 90 A.3d 300 (2014).

2011Thus, it is not even clear that the exhibit is an accurate representation of the plaintiffs net income at the time the prenuptial agreement was executed. 10 “Normally, when a portion of the court’s financial order is found to be flawed, we return the matter to the trial court for a new hearing on the ground that in marital dissolution jurisprudence, financial orders often are interwoven.” Rosato v. Rosato, 77 Conn. App. 9, 20 , 822 A.2d 974 (2003). “[0]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideration of all financ

2011Thus, it is not even clear that the exhibit is an accurate representation of the plaintiffs net income at the time the prenuptial agreement was executed. 10 “Normally, when a portion of the court’s financial order is found to be flawed, we return the matter to the trial court for a new hearing on the ground that in marital dissolution jurisprudence, financial orders often are interwoven.” Rosato v. Rosato, 77 Conn. App. 9, 20 , 822 A.2d 974 (2003). “[0]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideration of all financ

2024We, therefore, remand this matter for a new trial on all financial orders.13 See Renstrup v. Renstrup, 217 Conn. 13 In light of this conclusion, we need not address the defendant’s additional arguments that the trial court improperly failed to award a portion of the plaintiff’s bonuses as part of the child support award and failed to apply the correct percentages for sharing unreimbursed medical expenses and childcare costs as required by the child support guidelines. 0 Conn. App. 1 ,0 11 Wald v. Cortland-Wald App. 252, 284, 287 A.3d 1095 (‘‘the mosaic doctrine . . . allows reviewing courts to

2023Because the court’s support orders, particularly its spousal support or alimony order, are informed by and reflective of the parties’ incomes and assets, as affected by the court’s other financial orders, the entirety of the mosaic must be refashioned whenever there is error in the entering of any such interde- pendent order.’’ (Citation omitted.) O’Brien v. O’Brien, 138 Conn. App. 544, 555 , 53 A.3d 1039 (2012), cert. denied, 308 Conn. 937 , 66 A.3d 500 (2013). ‘‘[O]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideratio

2023Because the court’s support orders, particularly its spousal support or alimony order, are informed by and reflective of the parties’ incomes and assets, as affected by the court’s other financial orders, the entirety of the mosaic must be refashioned whenever there is error in the entering of any such interde- pendent order.’’ (Citation omitted.) O’Brien v. O’Brien, 138 Conn. App. 544, 555 , 53 A.3d 1039 (2012), cert. denied, 308 Conn. 937 , 66 A.3d 500 (2013). ‘‘[O]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideratio

2016Therefore, to conclude that the trial court abused its discretion, we must find that the court either incorrectly applied the law or could not reasonably conclude as it did." (Citation omitted; internal quotation marks omitted.) Mensah v. Mensah , 145 Conn.App. 644 , 651-52, 75 A.3d 92 (2013). *728 *192 "We next note that our review of financial orders entered by a trial court in a dissolution matter is governed by the mosaic doctrine.

2016Therefore, to conclude that the trial court abused its discretion, we must find that the court either incorrectly applied the law or could not reasonably conclude as it did." (Citation omitted; internal quotation marks omitted.) Mensah v. Mensah , 145 Conn.App. 644 , 651-52, 75 A.3d 92 (2013). *728 *192 "We next note that our review of financial orders entered by a trial court in a dissolution matter is governed by the mosaic doctrine.

2015A financial order is severable when it is not in any way interdependent with other orders and is not improperly based on a factor that is linked to other factors.’’ Smith v. Smith, 249 Conn. 265, 277 , 752 A.2d 1023 (1999). ‘‘In other words, an order is severable if its impropriety does not place the correctness of the other orders in question.’’ (Internal quotations marks omitted.) Maturo v. Maturo, supra, 296 Conn. 124–25.

2015A financial order is severable when it is not in any way interdependent with other orders and is not improperly based on a factor that is linked to other factors.’’ Smith v. Smith, 249 Conn. 265, 277 , 752 A.2d 1023 (1999). ‘‘In other words, an order is severable if its impropriety does not place the correctness of the other orders in question.’’ (Internal quotations marks omitted.) Maturo v. Maturo, supra, 296 Conn. 124–25.

2011“The rendering of a judgment in a complicated dissolution case is a carefully crafted mosaic, each element of which may be dependent on the other.” Ehrenkranz v. Ehrenkranz, 2 Conn. App. 416, 424 , 479 A.2d 826 (1984). “[0]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideration of all financial orders even though the review process might reveal a flaw only in the alimony, property distribution or child support awards.” Casey v. Casey, 82 Conn. App. 378 , 389 n.9, 844 A.2d 250 (2004).

2011“The rendering of a judgment in a complicated dissolution case is a carefully crafted mosaic, each element of which may be dependent on the other.” Ehrenkranz v. Ehrenkranz, 2 Conn. App. 416, 424 , 479 A.2d 826 (1984). “[0]ur courts have utilized the mosaic doctrine as a remedial device that allows reviewing courts to remand cases for reconsideration of all financial orders even though the review process might reveal a flaw only in the alimony, property distribution or child support awards.” Casey v. Casey, 82 Conn. App. 378 , 389 n.9, 844 A.2d 250 (2004).

2004See, e.g., Krafick v. Krafick, supra, 234 Conn. 806 ; Sunbury v. Sunbury, 210 Conn. 170, 173-75 , 553 A.2d 612 (1989).

2004See, e.g., Krafick v. Krafick, supra, 234 Conn. 806 ; Sunbury v. Sunbury, 210 Conn. 170, 173-75 , 553 A.2d 612 (1989).