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C. NATURE OF CASE
Plaintiff asserts that the following facts are documented court records at the
Bridgeport Superior Court in the case
of
Saverio A. Sorrentino
v
Kathryn M
Sorrentino, Docket No. FBT-FA-06-4015691-S in which the trial court judge,
Mark T. Gould, presided over a a series of hearings from October 15, 2009 to
May 20, 2010, in which he violated Kathryn M Sorrentino's Constiutional Rights
and incarcerated her.
D CAUSE OF ACTION
CLAIM I: THE TRIAL COURT MARK T. GOULD ERREDNIOLATED
KATHRYN M. SORRENTINO'S CONSTITUTIONAL RIGHT TO DUE PROCESS
WHEN HE FAILED: A) TO ADVISE KATHRYN M. SORRENTINO OF HER
RIGHT TO APPOINTMENT OF COUNSEL
AND
B) FAILED TO APPOINT
COUNSEL IN A CONTEMPT HEARING IN WHICH SHE FACED POTENTIAL
INCARCERATION,
AND
IN DOING SO VIOLATED HER CONSTITUTIONAL
RIGHT TO DUE PROCESS.
STANDARD FOR REVIEW:
Plain Error Doctrine.
Kathryn
M
Sorrentino relies on the facts as presented above and
supported by the transcript of the October 15, 2009, hearing and the December
15, 2009 hearing to support her assertion that Mark T Gould's failure to timely
appoint counsel presents extraordinary circumstance as reasoned
in tate
v
Go/ding supra 2 3 Conn. 239, . In addition, the plain error doctrine is reserved
for truly extraordinary situations where the existence of the error is so obvious
that it affects the fairness and integrity
of
public confidence in the judicial
proceedings.
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Kathryn M Sorrentino was denied her Constitutional right to due process
when Mark
T
Gould failed to advise Kathryn
M
Sorrentino of her right to
appointment of counsel and failed to appoint counsel t the commencement of
the hearing/trial on the motion for contempt. Therefore the first issue
of
this case
presents the straightforward and relatively simple rule that a defendant can be
put to trial only after the application of his or her due process right to counsel,
and that when the trial court fails to provide said right, all subsequent
ruling/orders are not upheld. Constitutional right to due process guarantees every
accused individual has a right to effective assistance of counsel.
The due process clause of the fourteenth amendment of the United Sates
Constitution guarantees the right to appointed counsel to any indigent civil
contemnor who might be incarcerated, Ridgeway v. Baker, 720 F.2d 1409, 1413
5
th
Gir. 1983)
1 Kathryn M. Sorrentino's Fourteenth Amendment Right to Counsel
Attaches in her Hearing/Tria l on Plaintiff's Motion for Contempt.
It is the defendant's interest in personal freedom, and not simply the
special Sixth and Fourteenth Amendment right to counsel in criminal cases,
which triggers the right to appointed counsel.
Lassitel} v
Dept.
o f
Social
ServicesorDurham
County, 45
U.S 18 1981). It would be absurd to
distinguish criminal from civil incarceration; from the perspective of the person
incarcerated, the jail is just as bleak no matter what the label used. In addition,
the line between criminal and civil contempt is a fine one, and is rarely as clear
as the state would have us believe.
The right to counsel, as an aspect
of
due process, turns not on whether a
proceeding may be characterized as criminal or civil , but on whether the
proceeding may result in a deprivation of liberty. Ridgeway v Baker, 720F.2d
1409 1413 1
Cir. 1983).
U.S. Supreme Court has long held that the Sixth Amendment grants as
indigent defendant the right to state-appointed counsel
in
a criminal case.
GIdeon v Wainwdght,
37
U.S 335
1963). And the U.S. Supreme Court has
held this same rule applies to criminal contempt proceedings (other than
summary proceedings. United
States
v
Dixon,
509 U. S 688 (1993).
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Although the Sixth Amendment (A1 does not govern civil cases, both the Fifth
Amendment (A1 and the Sixth Amendment (A
1
are incorporated into and
thereby enforced by the Fourteenth Amendment. The United States Supreme
Court and the Connecticut Supreme Court have looked to the analysis of the
Fifth and Sixth Amendments by the Courts, to establish the process for
application o the Fourteenth Amendment to civil cases, including civil contempt
cases.
The U.
S.
Supreme Court
in
Turner
v
3 U 2507 2011) fully
analyzed the application o the constitutional amendments regarding due process
with the State
o
South Carolina's tradition/law that does not provide counsel for
defendants
in
a hearing/trial for civil contempt.
In
the United States Supreme
Court's decision, the trial court's ruling was overturned but not based on South
Carolina's failure to proved counsel. It was overturned because
in Turner
v
Rogers,
the trial court failed to provide, at a hearing/trial for contempt,
constitutional due process right
in
accordance to/enforced by state statutory
law/ safeguards
requiring the very literatim
o
a finding that the contempt
was willful The United States Supreme Court thus identifying exception to right
to counsel that exists but only i f trial court adheres to the statutory structure o a
contempt hearing/trial which mandates that any finding o contempt must be
supported by the fact that the contempt was willful. Allowing no legal support for
judicial presumption: or appearance , nor any judicial discretion based on
capability. Simply put, the defendant must be shown/proved by the
plaintiff/evidence submitted, to have the ability to comply with
an
order. Thus
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The right to counsel is merely a logical extension
of
the right to counsel
in criminal cases in which an accused is incarcerated. The court's recognition of
a
due
process right to counsel in civil contempt cases in which the contemnor
might be imprisoned reflects a judgment that it is the defendant's interest in
personal freedom, and not simply the special Sixth and Fourteenth Amendments'
right to counsel in criminal cases, which triggers the right to counsel. .. Mastin
v
Fel/erhoff, supra; Ridgeway
v
Baker, supra; Thus cases discussing the nature
of the Sixth Amendment right to counsel in criminal cases are instructive
regarding the scope
of the
Fourteenth Amendment right to counsel in civil cases
in which a litigant might be incarcerated The trial court has an obligation to
inform the potential contemnor
of
his right to appointed counsel to ensure that
any waiver
of
the right to counsel is intelligent and competent. In re Jessen, 738
F
Sup.
960 963
WO.N.C.
1990);
see
Johnson v Zerbst 304 US 58
S CI 8 LEd.
1461 (1938); The constitutional right to an accused to be
represented by counsel invoke, of itself, the protection of a trial court, on which
the accused ... whose life or liberty is at stake ... is without counsel. This protecting
duty imposes the serious and weighty responsibility upon the trial judge of
determining whether there is an intelligent and competent waiver
of
the accused.
While an accuse may waive the right to counsel, whether there is a proper waiver
should be clearly determined by the trial court, and it would be fitting and
appropriate for that determination to appear on the record, Jonson
v
Zerbst
supra.
In Sorrentino
v
Sorrentino, as in Emerick, the trial court Mark
T
Gould did not
advise Kathryn
M
Sorrentinio of either her right to be represented by
counselor
her
right to appointed counsel
in
the event that she was indigent, and
in
Sorrentino, like wise, Judge Mark
T
Gould failed to state on the record that he
had eliminated incarceration as a possible penalty in the event that Kathryn M.
Sorrentino was adjudicated in contempt. Thus Mark
T
Gould's failure to advise
of
right to counsel and then upon finding
of
indigence to appoint counsel for
Kathryn
M
Sorrentino ran afoul of the Sixth and Fourteenth Amendment to the
United States Constitution, as well as, CT. Practice Book Sec. 25-63.
2. Kathryn M.Sorrentino's Right to Counsel Attached at the Commencement of
the HearinglTrial on Saverio A. Sorrentino's Motion for Contempt.
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Kathryn M. Sorrentino appeared before Mark T. Gould on December 15,
2009 for a hearing on Save rio Sorrentino's motion for contempt (filed September
18 2009
see entry 196.88). Upon being duly sworn
in,
the two issues
of
the
motion for contempt were presented Kathryn
M.
Sorrentino for her testimony
a
the listing
of
the Curtis Terrace property by Kathryn
M.
Sorrentino, for which Mark
T Gould found her not in contempt at the time of the hearing and, b) the payment
of
the Curtis Terrace mortgage by Kathryn
M.
Sorrentino, pursuant to the parties'
settlement agreemenUdivorce decree. The record clearly shows and it
is
undisputed that Mark
T
Gould did not advise the Kathryn
M.
Sorrentino
of
any
right to appointment
of
counsel, nor was counsel appointed to here at this time.
The United
States Supreme Court in
Kirby
v
Illinois 4 6
U S 682 1972)
has determined right to counsel, Attaches upon commencement of adversarial
judicial proceedings against the defendant. Whether by way of formal charges,
preliminary hearing, indictment, information or arraignment.
In Crist v. Bretz, 437 U.S.28 (1978) the U.S. Supreme Court determined
(although
in
Bretz analyzing the attachment
of
double jeopardy) Fourteenth
Amendment protections include right to counsel and therefore Bretz
is
properly
used by the Defendant to support her argument that right to counsel attaches at
the start of a hearing/trial, and not as
in
the Defendant's case at the tail end of
what turned into a trial spread out over the course of six months. The Crist Court
determined, The federal rule that jeopardy attaches in a jury trial when the jury
is
empaneJled and sworn, a rule that reflects and protects the defendant's interest
in retaining a chosen jury,
is
an integral part of the 5
th
Amendment guarantee
against double jeopardy made applicable to the States by the Fourteenth
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Amendment. Hence, a Montana statute providing that jeopardy does not attach
until the first witness is sworn cannot constitutionally be applied in a jury triaL
Here, the Crist Court although addressing the issue
of
attachment
of
right to
Fourteenth Amendment/double jeopardy by ruling that attachment of right
precedes the swearing in
of
witness, allows reasoning
of
due process violation to
support Defendant's argument that defendant's right to counsel attached [at
least] upon her being sworn in .
3. The Reviewing Court Need Not Determine Whether the Error Was Ha rml ess.
In Emedck, Where a trial court has failed to inform a defendant of his
constitutional right to appointed counsel, WE WILL NOT ATIEMPT TO
DISCERN WHETHER THE ERROR WAS HARMLESS. SUCH FAILURE IS
REVERSIBLE ERROR. See
Johnson v Zerbst, supra, In
Re
Jessen, supra,
GIdeon v Waindght, supra (no harmless error analysis where a criminal
defendant was deprived
of
his constitutional right to counsel).
The failure
to
advise the defendant properly is fatal
not
only
to
the finding of contempt,
but
also to the orders related thereto:
the order for
the payment of counsel
fees
arising
out
of
the
finding
of
contempt the
finding that
an arrearage
existed and the order to
pay
the
arrearage.
Emenckcontinues, Finally, the risk
of
an erroneous deprivation
of
liberty by
refusing to appoint counsel for the indigent petitioner is high. The courts have
long recognized the importance of a lawyer in protecting the right to liberty. See
Gideon
v
Wainright, 372
US
supra; the presence
of
counsel goes to the very
integrity of the fact-finding process. As the Supreme Court has noted:
Even the intelligent and educated layman has small and sometimes no skill in
the science
of
law ... he lacks both the skill and knowledge adequately to prepare
his defense, even though he have a perfect one. He requires the guiding hand
of
counsel at every step
in
the proceeding against him. Without it though he be not
guilty, he faces the danger of conviction because he does not know how to
establish his innocence.
Powell v Alabama, 287 U
S
45 69 53
SeT
55 64
77 L Ed 158 (1932).
CLAIM 2: THE TRIAL COURT
MARK
T. GOULD RULED WITHOUT
JURISDICTION/ERREDNIOLATED THE KATHRYN M. SORRENTINO'S
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CONSTITUTIONAL RIGHT TO DUE PROCESS WHEN HE FAILED/REFUSED
TO RULE ON THE KATHRYN M. SORRENTINO S STATED OBJECTION TO
HEARING ON CONTEMPT MOTION FOR HER FAILURE TO PAY
MORTGAGE AND ARREARAGE AND
N
DOING SO OVERRULED THE
KATHRYN M. SORRENTINO S OBJECTION TO HEARING
ON
ISSUE OF
MORTGAGE AND ARREARAGE PAYMENTS.
STANDARD FOR REVIEW:
Plain Error Doctrine.
Kathryn M. Sorrentino claims plain error doctrine
in
that Mark T. Gould is
without jurisdiction to refuse to rule
on
a motion presented. Defendant relies
on
CT.G.S.
Sec. 4b-81 (a), where cited
in
Bunche
v.
Bunche, 180 Conn. 285 (1980), it was
reasoned,
... the statute that enables the trial court to transfer property
in
a marital
dissolution action, the court does not retain continuing jurisdiction over any
portion o the judgment that constitutes an assignment o property.
1. Kathryn M. Sorrentinoi Statement Advising Mark T. Gould that the Issue o Her
Payment o the Mortgage for the Marital Property has Been Heard and Ruled
Upon Before by a Court o Competent Jurjsdiction was a Legally Sufficient
Objection to Hearing on Said Issue and Constitutes Preservation
o
a Claim
o
Error and is Therefore Subject to Review by Appeal.
In
amar
Rowe v Supedor Court; Judicial Distr ict ofNewHaven
The plaintiff-appellant was found guilty on two counts of contempt o
court.
In
his writ o error, the plaintiff contended that the second finding of
contempt violated the common law, as well as his constitutional rights to due
process and to protection against
double jeopardy. Before the Trial Court rendered its second finding o contempt,
the attorney for the plaintiff stated the following objection: I understand that the
likelihood
is
that the court will find us
in
contempt, but I think that.
..
this question
basically, it's essentially the same fact scenario and it is just rewording the
question, and under the circumstances I would ask the court not to impose a
sentence that is consecutive because its all one set
o
circumstances that's being
questioned about. .. The appeal court reasoned, Although the objection was not
stated artfully ... the
plaintiff did assert the narrowest theory o the claim that he
raises
in
his writ
o
error-namely that he could not be punished for multiple
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contempt's ... Because the trial court appeared to have understood and rejected
this argument, the appeal court found that the plaintiff had preserved the issue
of
double jeopardy.
Kathryn
M.
Sorrentino declared to Mark
T
Gould that the issue of the
payment
of
the mortgage had been heard and ruled upon before by the Trial
Court (Pinkus, J.) and that the Trial Court (Pinkus, J.) had found that Kathryn
M.
Sorrentino as not
in
contempt of court (Transcript: March 26, 2009, pg.16, lines
3 4
5). The Trial Court (Gould, J.) responded by stating, All right. I
understand what your claims are. (Transcript: December 15, 2009, pg. 22, lines
9 -15). This on top
of
what transpired at the hearing on October 15, 2009,
wherein Judge Gould referred the issues of the motion for contempt back to
Judge Pinkus, is evidence, on the record, that Judge Gould understood that
issue of the mortgage payments had been heard and ruled upon. Here, like in
Rowe though presented not artfully, Kathryn M. Sorrentino did assert her
objection to the issue of the payment of the mortgage on the grounds that she
had already been found to have not been
in
contempt for the same charge.
2. Trial Court Mark T. Gould's Failure/Refusal to Rule on Kathryn M. Sorrentino's
Objection to Contempt Hearing
on
Issue of her payment of Mortgage
as
Denial.
In
Ahneman v Ahneman, 243 Conn. 47 Conn. Supreme Court 1998)
The trial court's decision not to consider the defendant's motions was the
functional equivalent of a denial of those motions. Like a formal denial, the effect
of
the court's decision refusing to consider the defendant's motions during
pendency of the appeal was to foreclose the possibility
of
relief from the court on
those issues, unless and until the resolution
of
the appeal required further
proceedings. Indeed, the refusal to consider a motion is more deserving of
appeal review than a formal denial, because the defendant not only has been
denied relief; she has been denied the opportunity even to persuade the trial
court that she is entitled to that relief ..
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.. We next consider whether the trial court had the discretion to refuse to
consider the defendant's post judgment motions concerning financial issues. We
consider this issue because it is inextricably linked to the nature of our remand.
Normally, when we conclude that the Appellate Court has improperly failed to
reach an issue concerning a decision by the trial court, we remand the case to
that court for consideration
o
the merits
o
that issue. Under our supervisory
powers over proceedings on appeal, however, this court also has the authority to
address the subject
o
the trial court's decision. See Practice book Sec. 4183;
Matza
v
Matza,
226 Conn. 66
(1993).
In the present case, our review o the propriety o the trial court's
decision is warranted because a remand to the Appellate Court for review in the
normal fashion would engender significant confusion. On the one hand, we have
characterized the decision
o
the trial court as the functional equivalent of a
formal denial o the motions at issue here, which suggests that, on remand, the
Appellate Court should perform its function in accordance with its normal scope
o
review, see e.g., Crowley v Crowley 46 Conn. App. 90 699
A d
1029
(1997).
( Orders [of trial court
in
domestic relations cases] will not be reversed
unless its finding have no reasonable basis in fact or it has abused its discretion,
or unless, in the exercise o such discretion, it applies the wrong standard o
law. ) On the other hand, however, because the trial court has not rendered any
factual or legal basis conclusions regarding the defendant's motions, the
Appellate Court cannot perform a review. Therefore, in order to avoid confusion,
we will review the propriety o the trial courts decision ourselves.
In
addition
invoking our supervisory powers to reach the merits
o
their claim concerning the
decision
o
the trial court in this present case will avoid the necessity of
inordinate further delay.
O Bymachow
v
O Bymachow, 10
Conn. App
521 A d
599.
The CT Supreme Court having considered the issue decided: Turning to
the merits, we agree with the defendant's assertion that the trial court's decision
to refuse to consider her motions on financial issues was improper. The simple
reason for that conclusion is that the trial court lacked the authority to refuse to
consider the defendant's motions.
CLAIM
3:
TRIAL COURT JUDGE MARK
T
GOULD ERRED/RULED WITHOUT
JURISDICTIONNIOLATED KATHRYN M. SORRENTINO S CONSTITUTIONAL
RIGHT TO DUE PROCESS WHEN IT HELD JURISDICTION OVER RULED ON
AN ISSUE THAT WAS ALREADY HEARD AND RULED UPON BY A COURT
OF COMPETENT JURISDICTION
STANDARD OF REVIEW:
Plain Error Doctrine.
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Kathryn
M.
Sorrentino relies on the plain error doctrine. Kathryn
M.
Sorrentino relies on the facts as presented above and supported by the transcript
of
the October 15, 2009, hearing and the December 15, 2009 hearing to support
her assertion that Mark
T.
Gould's refusal to hear and thereby over-ruling her
objection constitutes a violation
of
her due process rights thereby presenting
extraordinary circumstance as reasoned
in State v Golding supra
213
Conn.
239, .. . In addition, the plain error doctrine is reserved for truly extraordinary
situations where the existence
of
the error is so obvious that it affects the
fairness and integrity
of
public confidence in the judicial proceedings.
Additionally, in Golding, .. under second prong
of
the analysis
we
must
determine whether the consequences
of
the error are so grievous as to be
fundamentally unfair or manifestly unjust.. .only
if
both prongs
of
the analysis are
satisfied can the appealing party obtain relief.
1. Kathryn M. Sorrent ino is Entitled
to
Claim the Fourteenth Amendment Double
Jeopardy Clause.
Kathryn M. Sorrentino appeared before the Trial Court Judge Mark T.
Gould on October 15, 2009 in a hearing on Saverio A Sorrentino's motion for
contempt (filed September 18, 2009). Judge Gould heard the issue
of
the listing
of the property
t
212 Curtis Terrace and upon attempting to consider the issue
of
the claim that Kathryn M. Sorrentino failed to pay the mortgage
for
same, she
stated (Transcript:
11/15/2009
P9. 5
lines 20-27, and
P9.
6
lines 1-5) that the
issue regarding the payment
of the
mortgage had already been heard by Judge
Pinkus and he had ruled that she was not
in
contempt. Judge Gould referred
Saverio A Sorrentino's motion for contempt back to Judge Pinkus. A hearing
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ensued
on
November 12, 2009, attended Saverio A. Sorrentino where the sole
issue presented was the listing of the property at 212 Curtis Terrace. Kathryn M.
Sorrentino was not present and because the motion was not in the file, Judge
Pinkus refused to hear the motion. Scheduled for December 15, 2009, for a
hearing on Save rio A. Sorrentino's motion for contempt (filed September 18,
2009).
Upon being duly sworn
in,
the two issues of the motion for contempt were
presented to Kathryn M. Sorrentino for her testimony a the listing of the property
by Kathryn
M.
Sorrentino, for which the Trial Court Judge Mark
T.
Gould found
Kathryn
M.
Sorrentino not
in
contempt and,
b
the payment
of
the Curtis Terrace
mortgage by Kathryn
M.
Sorrentino, pursuant to the parties' settlement
agreement/divorce decree (DS-131 and 143. Kathryn
M.
Sorrentino
on
the record
(Transcript
12/15/2009
pg. 22, lines 9-15) advised the Court that the issues of
Saverio A. Sorrentino's motion for contempt were already heard AND RULED
ON by the Court (Pinkus, J.) Transcript March 26, 2009, P9.1, lines 3,4&5}.
Kathryn M. Sorrentio's argument is well proved in the reasoning and decisions of
the United States Supreme Court.
In
Smalis
v
Pennsyvania
7
U.S. 140
(1986) the Court reasoned:
... Whether the trail
is
to a jury or, to the bench, subjecting the defendant to post
acquittal fact finding proceedings going to guilt or innocence violates Double
jeopardy Clause. The constitutional prohibition against double jeopardy was
designed to protect an individual from being subjected to the hazards of trial and
possible conviction more than once for an alleged offense .
..
through out most
of
our history, this clause was binding only against the Federal Government. In
Palko v Connecticut 302 U.S.
319 (1937), the Court rejected an argument that
the Fourteenth Amendment incorporated all the provisions
of
the first eight
Amendments as limitation on the States and enunciated the due process theory
under which most of those Amendments do now apply to the States. Some
guarantees in the Bill
of
Rights, Justice Cardozo wrote, were so fundamental
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they are of the very essence
of
the scheme
of
ordered liberty and neither liberty
nor justice would exist if they were sacrificed. But the double jeopardy clause,
like many other procedural rights of defendants, was not so fundamental; it could
be absent and fair trials could still be had.
Of
course, a defendant's due process
rights, absent double jeopardy consideration per se, might be violated if the State
created a hardship so acute and shocking as to be unendurable, but that was
not the case
in
Palko.
In
Benton
v.
Maryland 395
US.
784,
794-95 (1969),
however, the Court concluded that the double jeopardy prohibition ... represents
a fundamental ideal in our constitutional heritage ... once it is decided that a
particular Bill
of
Right guarantee is fundamental to the American scheme of
justice,
'
the same constitutional standards apply against both the State and
the Federal Governments. Therefore, the double jeopardy limitation now applies
to both federal and state governments and state rules on double jeopardy, with
regard to such matters as when jeopardy attaches, must be considered in the
light of federal standards.
In doctrine
of Benton v. Maryland
395 US. 784, puts the issues in the
present case
in
a perspective quite different from that which the issues were
perceived in Hoag
v.
New
Jersey Supra. The question is no longer whether
collateral estoppel is a requirement of due process, but whether it is part of the
Fifth Amendment's guarantee against double jeopardy, and if collateral estoppel
is embodied
in
that guarantee, then it's applicability
in
a particular case is no long
a matter to be left for a state court determination within the broad [397 U.S.436,
443] bounds
of
fundamental fairness, 'but a matter of constitutional fact we must
decide through an examination
of
the entire record. Cf.
New York Times
Co.
v.
Sullivan
376 US. 254, 285,
728-729d; Nemotko v. Maryland 340
US 268, 271,
327; Collateral estoppel is an awkward phrase, but it stands for an extremely
important principle in our adversary system of justice. It means simply that when
an
issue
of
ultimate fact has once been determined by a valid and final judgment,
that issue cannot again be litigated between the same parties
in
any future
lawsuit.
'Although first developed
in
civil litigation, collateral estoppel has been an
established rule
of
federal criminal aw at least since this Court's decision more
than 50 years ago
in United States
II:
Oppenhiemer
4
U W 85
As Mr. Justice
Holmes put the matter
in
that case. It cannot e that the safeguards
of
the
person, so often and so rightly mentioned with solemn reverence, are less than
those that protect from liability in debt.
'242
US at 87, 37 S Ct. at
69.7.
As a
rule
of
federal law, therefore, '(I) t is much too late to suggest that this principle is
not fully applicable to a former judgment in a criminal case, either because of
lack
of
'mutuality' or because the judgment may reflect only a belief that the
Government had not met the higher burden
of
proof exacted
in
such cases for
the Government's evidence as a whole although not necessarily as to every link
in the chain.' United States II: Kramer 89 F 2d 909 913 The ultimate question
to be determined, then, in the light of Benton II: Maty/and supra is whether this
established rule of federal law is embodied in the Fifth Amendment guarantee
against double jeopardy. We do not hesitate to hold that it is. For whatever else
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IMPLICATION AND CONJECTURE barred when considering contempt appeal.
Id 460
Kathryn M. Sorrentino's failure to pay mortgage as per settlement
agreement/divorce decree is due to Save rio A. Sorrentino's breach
of
settlement
agreement/divorce decree regarding monies that were to be paid to Kathryn M
Sorrentino. Saverio A. Sorrentino has, via court order, modified amount
of
money
paid to Kathryn
M
Sorrentino does not remove her dependency on sum total
of
settlement agreement/divorce decree, but rather it shows that Saverio A.
Sorrentino is responsible for Kathryn M Sorrentino's inability to pay mortgage,
and that through no fault
of
her own has been unable to adhere to settlement
agreement/divorce decree and that Kathryn M. Sorrentino's failure to adhere to
settlement agreement/divorce decree IS
NOT
WILLFUL.
.. the contemnor, through no fault
of
his own, was unable to obey the court's
order.
Tobey v Tobey 65 Conn 742, 746, A d2 1974)
The Trial Court (Pinkus J.) found as much at the contempt hearing stating
(to the
Plaintiff), 1don't have the tools to fix your problems. I don't have the tools, [to]
have you
go
back to
what
you may heave been, earned at one time, get the
houses valued at
what
they were at one time, and sold. I don't have the ability to
do that. ... For the record your motion for contempt is Lcan't find that
there is any willful violation of a court order. (Transcript:
3/2/2009
P9 15, lines
5-10 and P9 , 1, lines 3-5) See: Schedule 8 (t) ,
CLAIM
5: THE
TRIAL
COURT
MARK
T.
GOULD ERREDNIOLATED
KATHRYN M. SORRENTINO S CONSTITUTIONAL RIGHT TO DUE PROCESS
WHEN IT
HELD
JURISDICTION ON
AN
ISSUE INVOLVING A
MARITAL
ASSET ALREADY
DISPOSED OF AT THE DISSOLUTION OF THE
MARRIAGE AND WHEN
HE ORDERED KATHRYN M. SORRENTINO TO
TRANSFER
(QUITCLAIM) PROPERTY TO
SAVERIO A.
SORRENTINO
PREVIOUSLY DISPOSED IN THE DIVORCE DECREE.
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STANDARD OF REVIEW:
Plain Error Doctrine.
Kathryn M. Sorrentino relies on the plain error doctrine. Asserting that Mark T
Gould erred/violated her due process rights when he held jurisdiction
on
a marital
asset that was disposed at the time of the parties divorce. For that issue Kathryn
M. Sorrentino believes review is plenary and must be decided by the application
of correcUlegallaws governing the issue.
Appellate review under the clearly erroneous standard is a two-prong
inquiry. [W] e first determine whether there is evidence to support the finding. If
not, the finding is clearly erroneous. Even if there is evidence to support it
however, a finding is clearly erroneous if
in
view of the evidence and pleadings
in
the whole record {this court} is left with the definite and firm conviction that a
mistake has been committed.
Buddenhagen
v
10
Conn 4
(1987),
quoling Doyle
v
Kulesza,
197,
Conn
101
(1985).
The courts judgment in an action for dissolution of a marriage is final and
binding upon the parties, where no appeal is taken there from, unless and to the
extent that the statutes, in common law or rules of court permit the setting aside
or modification of the judgment.
Bunche
v
Bunche, 180 Conn.
285
On May 27 2007 the Kathryn M. Sorrentino and Saverio
A.
Sorrentino
signed a settlement agreement that was incorporated into the divorce decree
on
November 29, 2007. Stipulated therein the disposition of the marital property.
The Trial Court, Judge Gould, at a hearing on April 7 2010, ordered Kathryn
M.
Sorrentino to quitclaim her portion of property to Saverio
A.
Sorrentino, property
that had already been disposed of in a settlement agreemenUdivorce decree.
Kathryn
M.
Sorrentino claims that
in
so ordering, Mark
T
Gould violated her due
process rights which resulted in Kathryn M. Sorrentino's incarceration (May 10
2010) for refusing to sign quitclaim and loss of property rights protected by
Fourteenth Amendment.
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1
Trial Court Judge Mark T Gould had no Jurisdiction Over the Issue of the
Marital Assets (Property Divisiont
The agreement was ordered incorporated ... into the dissolution decree. A
judgment rendered
in
accordance with such a stipulation
of the
parties
is to
be
regarded and construed
as a contract. (Internal quotation marks omitted).
Issler v
IssIe ; 250 Conn. 22fi
234-34
737A 2d
383 (1999). See also
Miha/yak
v Mtha/yak, supra 30 Conn. App., 522 Judgment that incorporates
separation
agreement
to be regarded as
contract and construed
pursuant
to
contract
law). [I] nterpretation of an agreement
is
a search for the intent of
the parties.
Lavigne
v
Lavigne, supra,
427-29. A judgment rendered
in
accordance with the stipulation of the parties is to be construed and regarded as
a binding contract. Caracansi
v
Caracansi. 4 Conn. App. 645. 650. 496 A
2d
225.
celt
denied. i97 Conn. 805. 499 A
2d
6 1985).
Construction of such
agreement
is an
issue of fact to be resolved by the trial court as the trier of fact,
and subject to our review under the clearly erroneous standard. See
Lavigne v
Lavigne.
3
Conn. App.
423 (1985)
It is not disputed that the parties settlement agreement was incorporated into the
dissolution judgment.
Therefore,
as In
Pasquariello
v
Pasquariello. 168 Conn. 579.
584 362
A2d 835 (1975). The ultimate issue for this court
is
whether the trial court, could
have concluded
as
it did. Accordingly, [o]ur resolution
of
the [Plaintiff's] claim
is
gUided
by the
gO-neral
principles
governing
the
construction of
contracts A contraot must
be
construed to effectuate the Intent
of the parties.
which is determined from the language used interpreted
in
the
light of the situation
of
the parties and the circumstances connected with the
transaction. (Internal quotation markes omitted).
Issler v Issler, supra.
250
Conn. 235
In Passamano v Passamano,
228
Conn. 85
CT
Supreme Coun (1993)
Under CT. General Statues Sec. 4b-81 (a), the statute that enables the trial
court to transfer property
in
a marital dissolution action, the court does not retain
continuing jurisdiction over any portion of the judgment that constitutes
an
assignment
of
property,
Bunch v 180 Conn. 284
429
A
2d 874
(1980). Therefore, a property division order generally cannot be modified by the
trial court after the dissolution decree is entered, subject only to being opened
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within four months from the date the judgment is rendered under General Statues
Sc. 52-212a. The trial court does retain continuing jurisdiction to modify or
terminate alimony and child support orders, unless the orders are based on a
stipulated agreement that expressly bars future modification. General Statues
Sec. 46b-86; Bernard v
Bernard, 214 Conn. 99 1990).
Although the court has jurisdiction to assign property in connection with
46b-81, that assignment is not modifiable. See Taylor II. Taylor,
57
Conn. App.
528,
533,
752
A.
2d 3
2000).
Moreover, property distributions
.
. cannot be
modified to alleviate hardships that may result from enforcement
of
the original
dissolution decree in the face of changes in the situation of either party. (Internal
quotation marks omitted.) Simmons v Simmons, 244 Conn.158, 183-84, 708 A.
2d 949 (1998).
Because the original decree required the plaintiff to pay the defendant for her
interest in the property prior to July 23, 1998, and he has not made a single
payment noncompliance on the part of the parties made strict adherence to the
terms
of
the [decree] impossible.
Niles v Ni/es,
9
Conn App
240, 245-4, 518
A. 2d 932 (1986)
It's undisputed that the issue
of
the Parties marital property was disposed
at the time of the dissolution of the marriage (See: settlement agreement,
paragraph 2
a,
b,
c,
and d) Therefore the Trial Court Judge Mark T Gould had
no jurisdiction to essentially order a modification
of
said agreement. For that
reason Mark T Gould's order should be reversed.
CLAIM 6: THE
TRIAL
COURT JUDGE
MARK
T. GOULD ERRED/ABUSED ITS
DISCRETION WHEN IT FAILED TO FIND
SUBSTANTIAL
CHANGE OF
CIRCUMSTANCE WHEN ISSUING AN ORDER TO MODIFY THE PARTIES
SETTELEMENT AGREEMENT/DIVORCE DECREE.
STANDARD OF REVIEW:
Kathryn
M.
Sorrentino believes review is plenary and must be decided by
the application of correct/legal laws governing the issue.
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In
Borkowski v. Borkowski, 228 Conn. 729, 738,38 A. 2d 100 (1994), The
CT. Supreme Court explained that the power of the trial court to modify an
existing order does not include the power to retry issues already decided. Thus
the court's inquiry is necessarily confined to a comparison between the current
conditions and the last court order. The court continued: Applicable to
dissolution actions . .is the principle that
and
adjudication by a court
having jurisdiction
of the
subject matter
and
the parties is
final and
conclusive not
only as to matters actually determined, but as
to
matters
which
the parties
might have litigated as incident thereto and coming
within
the
legitimate
purview
of the
subject matter of
the
action . Id.,
39.
1 Modrtication of Settlement Agreement Must be Supported by SUbstantial
Change of Circumstance.
In Grino/d
v
172 Conn.
192 197) the plaintiff was estopped from
seeking a modification
of
the parties' settlement agreement, the trial court found
that the plaintiff failed to establish by the evidence a substantial change
in
circumstances. The short answer to this is that our law permits modification
of
support obligations when circumstances of the parties change.
Turner
v
Turner.
219
Conn. 7 3 1991).
CLAIM
7: THE TRIAL COURT
JUDGE
MARK T.
GOULD
ERRED/ABUSED ITS
DISCRETION WHEN
IT
FOUND THAT
KATHRYN
M. SORRENTINO HAD
APPARENTLY
AGREED
TO THE FORMULATED
PLAN
FOR PURGE
SUBMITTED TO THE COURT.
STANDARD FOR REVIEW:
Kathryn M Sorrentino believes review is plenary and must be decided by
the application of correct/legal laws governing the issue.
1 Kathryn M. Sorrentino Did Not Agree To The Formulated Plan And
Therefore Mark T Gould Had No Authority To Order The Plan Into his
Judgment.
The facts of this case clearly show, evidenced above and
in
transcripts,
that Kathryn
M
Sorrentino refused to sign the quitclaim, which was part
of
the
formulated plan devised submitted for the purge by Saverio
A
Sorrentino,
because inter alia, it was a conflict of the parties court ordered settlement
agreement, wherein it was stipulated that marital properties would be sold and all
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debt
listed on the parties affidavits would be paid from the proceeds of the sale.
The Mark T Gould stated in his articulation that there was apparently
an
agreement. Kathryn M. Sorrentino asserts that there is nothing on record to
support that finding.
An Agreement unwritten means nothing; but rather intentlactions/admittings, of
the parties.
anni v Dina Corporation
7Conn
App. 2009).
Here, the
record (Transcript: May 7 2010 and April
7
2010) clearly shows that at no time
did Kathryn
M.
Sorrentino agree to the formulated plan, expressly, at no time did
Kathryn M. Sorrentino agree to quitclaim her property. As on record, and as
presented above, Mark
T
Gould's colloquy with Kathryn
M.
Sorrentino shows a
clear declaration by Kathryn M. Sorrentino that it was not her plan and that she
did not fully understand it. Additionally, the formulated plan when reduced to
writing as ordered by Judge Gould, was not signed by Kathryn M. Sorrentino, as
asserted by her court appointed attorney and ultimately she was incarcerated for
refusing to sign the plan, which apparently had been reduced sua sponte by
Judge Gould to a single stipulation/oral order to quitclaim her portion of the
marital property in Newtown to Saverio A. Sorrentino. Here, it could be
reasonably argued that, on top of it all, Kathryn M. Sorrentino refusal to sign
quitclaim was justified under the Transparently Invalid Order exception.
In
re:
Providence Journal Company, 809 F.2d 63 (1st cir.1986), the court
addressed an order entered by a court clearly without jurisdiction,
.
. Nonetheless, court orders are not sacrosanct. An order entered by a court
clearly without jurisdiction over the contemnors or the subject matter is not
protected by the collateral bar rule. Were this not the case, a court could wield
power over parties or matters obviously not within its
authority a
concept
inconsistent with the notion that the judiciary may exercise only those powers
entrusted by law.
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CLAIM
8:
APPEAL:
THE
TRIAL
COURT
MARK
T GOULD
VIOLATED KATHRYN M SORRENTINO S CONSTITUTIONAL
RIGHT
TO A
SPEEDY
TRIAL WHEN HE FAILED/REFUSED TO
HEAR
AND RULE UPON THE
MOTIONS
SHE
FILED.
STANDARD FOR REVIEW
Plain Error Doctrine
Abuse of Discretion
Mark T to hear and rule upon the motions filed by Kathryn
M. Sorrentino and thereby violated her right to a speedy trial as provided for her
in the sixth amendment of the United States Constiution.
The Speedy Trial Clause of the Sixth Amendment to the United States
Constituion proveds that (i)n all criminal prosecutions, the accused shall enjoy
the right to a speedy triaL The Clause protects the defendant from delay
between the presentation
of
the indictment or similar charging intrument and the
beginning of trial.
In
Barker
v
Wingo (1972), the Supreme Court developed a four-part test
that considers the length
of
the delay, the reasons for the delay, the defendant's
assertion
of
his right to a speedy trial, and the prejudice to the defendant. A
violation of the Speedy Trial Clause is cause for dismissal with prejudice of a
criminal case.
The abuse
of
discretion standard applies to a trial court's decision on a motion
for contempt.
Sablowsky
v
Sablosky, 58 Conn.
713,
721
, 784 A 2d
890 2001).
The facts
of
this case, however, present to question
of
whether a trial court has
the discretion to refuse to consider a party's motion for contempt. We have
already squarely addressed this issue, concluding that, in the absence of an
extreme, compelling situation, a trial court that has jurisdiction over an action
lacks authority to refuse to consider a litigant's motions.
Ramin
v
Ramin,
281
Conn.
324
2007)
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Connecticut Practice Book Sec. 11-19
February 2010 to September 2010 the trial court judge Mark T. Gould) failed to
hear and rule upon the properly filed and served motions of Kathryn Sorrentino
(with the exception of denying her motions for articulations and stay concerning
her appeal). Most importantly, two Motions (OS-206.80 and OS-227.50) should
have been heard because they directly related to the eight-month, on going
hearing. Motions OS-206.80 and OS-227.50 are Motions For Contempt for
Saverio A. Sorrentino's failure to pay the mortgage on the property located at 27
Plumtrees Road, Newtown, Connecticut. Wherein they: a) counter Save rio
A
Sorrentino's Motion for Contempt alleging Kathryn M. Sorrentino's failure to pay
the mortgage on their property in Fairfield, Connecticut, thus giving credence to
Kathryn
M.
Sorrentino's claim that Saverio A. Sorrentio's claim is
equitably
estopped. This illustrates the legal maxim: IIhe who seeks equity, must do
equity
. I
And
b) it would have
shown
the evidence that proved Kathryn
M.
Sorrentino was not responsible for paying the mortgage unless she received
$1,000.00 weekly from the Save rio A. Sorrentino (See transcript dated January
24,2008, pg. 4, lines 10-14) in which he swears under oath:
I
had
a-the
plaintiff had a $1,000.00 per week obligation, and the defendant was supposed,
out of that, pay the mortgage. The facts and transcripts prove that Judge Gould
had Kathryn
M.
Sorrentio's Motion (206.80 and later re-filed
as
227.50)
in
front of
him at several hearings and f iledl refused to hear and rule upon them.
According
to Ramin v. Ramin, 281 Conn. 324 (2007), Mark T. Gould lacked the
authority to do so. And according to the Connecticut Practice Book Sec. 11-19
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(A 12) Judge Mark T Gould had a time limit for deciding short calendar matters.
He took papers for Defendant's Motion for Clarification (214) twice from the
short calendar and did not rule
on it
Mark T. Gould left the Bridgeport Court
house in September 2010 without hearing or ruling on Kathryn
M
Sorrentino's
motions.
Settled law dictates that Judge Gould lacked the authority to not hear and
rule Kathryn
M
Sorrentino's motions (See FBT FA-06-4015691-S docket entry
numbers: 203.89, 206.80, 214, 227.50 and 250).
Atty. McGuiness: Briefly, it came to my attention through my client that
there were other certain motions down, not that I'm involved
in
any
of
this.
The Court:
Mm-hmm.
Atty. McGuiness: I was court-appointed specifically for the motion for
contempt.
Atty. McGuiness: But there are other outstanding motions that she has that
she wanted to be heard on. I know the Court doesn't have time today but I
don't know what the Court - the plan was, because she has a number
of
motions
of
contempt that pretty much
dovetail-
The Court: I understand that. Atty.
McGuiness-the
motion that the Court's
hearing now.
The Court: ... 1will have a report-back date
of
next Monday, and at that
time when we have the report-back date we will take care
of
the other
outstanding motions. (Transcript date: May 10, 2010, pg. 14, lines 1-25).
Mark
T
Gould court failed to hear Kathryn M. Sorrentino's motions on the
next Monday as promised and thus violated her right to a speedy trial as
provided for her
in
the sixth amendment
of
the federal Constitution (See
Transcript date: May 17, 2010).
CLAIM
9: THE
TRIAL
COURT JUDGE
MARK
T
GOULD ABUSED ITS
DISCRETION/ERRED WHEN IT RULED THA T KATHRYN M. SORRENTINO
HAD THE
ABILITY
TO PAY THE MORTGAGE
AND
A $50,000.00
ARREARAGE
BASED
ON HER GOOD HEALTH, INTELLIGENCE,
AND
BACKGROUND
IN
EDUCATION AND TEACHING.
STANDARD FOR REVIEW
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Plain Error Doctrine
Mark T. Gould failed to find a substantial change in circumstances as
required by Connecticut General Statutes 46b-86 et seq.
Kathryn M. Sorrentino asserts that the Trial Court Judge Mark T. Gould
abused its discretion when it determined she had an ability to pay/earning
capacity with which she should have paid the monthly mortgage and a
$50,000.00 arrearage. Mark
T.
Gould's Response to Order for Articulation filed
10/29/2011, Ordered sua sponte, states his reason for finding Kathryn M.
Sorrentino in contempt for failure to the mortgage and arrearage: The court
... found that the defendant, in good health, intelligent and with a background in
education and teaching, had an ability to make payments under a plan as
requested by the plaintiff
.
. The transcripts
o
December 15, 2010 show that
Saverio A. Sorrentino presented no evidence to Mark T. Gould
or
otherwise to
support the Court's finding. Kathryn M. Sorrentino's own testimony that was
accepted by Mark
T.
Gould indicated that she had never been a teacher, nor
does she
hold a teaching certificate, nor does she have a background in
education, nor had she worked in 18 years. Mark
T.
Gould accepted Kathryn
M.
Sorrentino's testimony: I have not ordered a payment schedule for you because
o
your testimony and your indication that you have not worked and do not have
a job .. (Transcript pg. 12, lines 3-5). The Trial Court (Gould, J.) abused its
discretion when it ruled on the Kathryn
M.
Sorrentino's ability to pay/earning
capacity when the Court has on record multiple financial affidavits
o
Kathryn
M.
Sorrentino filed with both the Superior Court and the Magistrate Court proving
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her to be indigent due to being a displaced homemaker o 18 years and solely
reliant on child support and alimony from Saverio A Sorrentino.
E OTHER L WSUITS
The Plaintiff has no other lawsuits in statae or federal court dealing with
the same facts involved in this action.
F
REQUEST FOR RELIEF
Wherefore Plaintiff prays this Court issue equitable relief as follows:
1 Issue injunctive relief commanding Defendant to reverse his Order.
2 Issue declaratory relief as this Court deems appropriate and just.
3
Issue other relief as this Court deems appropriate and just.
4 Award Plaintiff her costs o litigation.
G
JURY DEM ND
The Plaintiff requests a jury trial.
Respectfully submitted
Suf\NVV\J
Kathryn M.Sorrentino Pro se
212 Curtis Terrace
Fairfield CT 06825
Tel: 203400-3712
Email: [email protected]
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DECL R TION UNDER PEN LTY OF PERJURY
The undersigned declares under penalty
o
perjury that she is the plaintiff
in the above action that she has read the above complaint and that the
inofmration contained in the complaint is true and correct. 28 U.S.C Sec. 1746;
18 U.S.C. Sec. 1621.
Executed at 915 Lafayette Boulevard Bridgeport Connecticut on March 13
2013.
Kathryn M Sorrentino
CERTIFIC TE
OF
SERVICE
THIS IS TO CERTIFY that a copy o the foregoing was mailed this date
postage prepaid to:
MARK
T
GOULD Judge
235 Church Street
New Haven CT
203 503-6800
80f\ MMJ
Kathryn M Sorrentino Pro se
212 Curtis Terrace
Fairfield CT 06825
Tel: 203400-3712
E-mail: [email protected]
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