Two family law cases decided by the Connecticut Supreme Court in the past year stood out from the rest. One of them yielded a new approach to the consideration of the enforceability of nonmodification of child support provisions. The other raised a novel issue concerning the interrelationship of the Uniform Fraudulent Transfer Act and dissolution of marriage judgments.

In Tomlinson v. Tomlinson, the Court addressed the issue of whether a separation agreement provision barring modification of an unallocated alimony and child support order is enforceable. The decision turned on the change in circumstances — physical custody of the minor children was shifting from the home of the recipient of alimony and child support payments to the home of the payor.