The Connecticut Appellate Court’s decision in Villao v. Paz (officially released Sept. 30, 2025) offers rare published guidance on the Connecticut appellate stay in family cases. For family law and divorce attorneys, this opinion clarifies how the automatic appellate stay operates under Practice Book § 61-11 (c)—and reminds attorneys that the exceptions are narrowly construed. 

Connecticut Appellate Stay in Family Cases: Background of Villao v. Paz 

After dissolving the parties’ marriage, the trial court ordered the defendant to pay her former husband $25,000 in attorney’s fees as part of the overall financial mosaic. The defendant appealed the financial orders, triggering the automatic stay under Connecticut appellate procedure. 

While that appeal was pending, the plaintiff filed a post-judgment contempt motion, claiming the defendant failed to pay child support, alimony, and the attorney’s-fee award. The trial court declined to make a finding of contempt for support arrearages but ruled that the fee award was “in the nature of support,” and therefore not stayed. It ordered payment within the week. 

The defendant sought expedited relief from the Appellate Court by filing a Motion for Review of the court’s decision, as allowed by Practice Book § 61-14 (a). On review, the Appellate Court vacated the trial court’s order, holding that the attorney’s fee award remained automatically stayed. 

How the Connecticut Appellate Court Interpreted the Automatic Appellate Stay 

Under Connecticut appellate stay rules, filing an appeal automatically stays “proceedings to enforce or carry out the judgment,” unless an exception applies or the trial court terminates the stay. 

In family matters, the exceptions—periodic alimony, child support, custody, and visitation—are construed narrowly. These carve-outs exist to protect ongoing needs such as child welfare or dependent-spouse maintenance during an appeal. 

The Appellate Court concluded that the attorney’s fee award was a lump-sum award that was part of the financial mosaic of the dissolution judgment and not periodic support. Because it was a lump-sum order rather than ongoing maintenance, the award was not a Practice Book § 61-11 (c) exception to the automatic appellate stay. The Court held that the award of attorney’s fees remained stayed unless the trial court properly terminated the stay under the factors described in Griffin Hospital v. Commission on Hospitals & Health Care, 196 Conn. 451, 456-57 (1985).

Practical Takeaways for Connecticut Family and Divorce Attorneys 

• Exceptions to the Connecticut appellate stay in family cases are narrowly construed. Only true periodic obligations—such as ongoing alimony or support—fall outside an automatic appellate stay. 
• Attorney’s-fee awards are automatically stayed unless the trial court terminates the stay. When a lump-sum fee award is part of the financial mosaic, counsel seeking enforcement must move to terminate the stay and meet the Griffin Hospital factors. 
• Exercise caution before enforcing financial orders during an appeal. Acting without a termination order can risk reversal or trigger unnecessary contempt litigation. Understanding how the appellate stay functions allows attorneys to protect their clients and judgments more effectively. 
• If seeking to act on an attorney’s fee award, ask the trial court to terminate the automatic stay. The motion should address the Griffin Hospital factors that the court uses to decide whether to terminate the stay. 

Why Villao v. Paz Matters for Connecticut Family Appeals 

Connecticut appellate courts seldom publish decisions on the Connecticut appellate stay in family cases, making Villao v. Paz a valuable precedent. It confirms that attorney’s fee awards tied to dissolution judgments function like other lump-sum financial orders. 

For family and divorce attorneys in Connecticut, understanding when the automatic appellate stay applies can prevent enforcement missteps, protect clients’ interests, and strengthen appellate strategy from the moment an appeal is filed. 

Have questions about a family appeal or the appellate stay? 
Contact Connecticut Appellate Law Firm to discuss your case.