State/Prov.  : Connecticut

Case name    : Zitkene v. Zitkus

Case #          : 140 Conn. App. 856

Court             : Connecticut Court of Appeals

Reviewed by : Laura Morgan

Main issue     : Divorce – Procedure – Jurisdiction

Evidence supported trial court’s finding, on basis of comity, that it lacked subject matter jurisdiction to hear former wife’s petition for dissolution of marriage in Connecticut, despite former wife’s allegation that foreign judgment was procured by fraud; former husband’s affidavit and copy of Lithuanian appellate court decision provided undisputed facts that former wife petitioned for dissolution in Lithuania, Lithuanian court entered divorce decree from which former wife appealed, seeking to excuse or defer her payment obligation under the dissolution agreement, she did not allege fraud on part of former husband, Lithuanian appellate court found no merit in her appeal, and former wife received “greater share” of marital property under Lithuanian divorce decree and retained benefits from that portion of award.


Laura Morgan is a Family Law Consultant. Laura is available for consultation, brief writing and research on family law issues throughout the country. She can be reached through her Web site.