Until this year, Connecticut’s appellate articulation rules were applied harshly to appellants. Briefly, what Practice Book §66-5 said, as clarified by the Supreme Court on numerous occasions since the rule was adopted in 1978, was that if a trial court decision was unclear, it was the appellant’s duty (unless the issue concerned an alternate basis to affirm, in which case it was the appellee’s duty) to try to get it clarified.
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