Background
C. P., a former Connecticut legislator, sought a civil protection order against Carol Riordan, a former neighbor and constituent. After Riordan made an unwanted early-morning visit to C. P.’s home in October 2023, C. P. told her to stop making contact. Riordan acknowledged that request and said she would comply.
Riordan nevertheless continued communicating with C. P. Over several days in February 2025, after C. P. had left office, Riordan sent emails to C. P.’s personal address referring to police services, analyzed phones, retaliation, harassment, and alleged misconduct. The trial court also found that Riordan menaced C. P. by repeatedly honking and revving her vehicle’s engine while driving toward or past her. The court granted a civil protection order under Connecticut General Statutes § 46b-16a, and Riordan appealed.
The Court’s Holding
The Appellate Court affirmed, holding that the trial court did not abuse its discretion in finding reasonable grounds to believe that Riordan had stalked C. P. and would continue doing so. C. P.’s credited testimony that she feared for her physical safety satisfied the subjective component of the statutory fear inquiry. The emails’ content and repetitive nature, combined with Riordan’s driving behavior, supported the objective finding that a reasonable person in C. P.’s position would fear for her safety. Riordan’s continued contact despite agreeing to stop, including her recent emails and conduct involving her vehicle, also supported the finding that the stalking was likely to continue.
The court further held that the trial court properly excluded Riordan’s proposed testimony that she herself had been harassed or followed. Riordan offered that evidence only to show that she was not delusional, not to establish that C. P. had stalked her or to challenge C. P.’s credibility on a material issue, so it was irrelevant to the protection-order proceeding. The court declined to review Riordan’s federal and state free-speech claims because her briefing was sparse, internally inconsistent as to whether the challenge was facial or as applied, and failed to analyze and apply relevant authority.
Key Takeaways
- A stalking-based civil protection order requires reasonable grounds to believe both that stalking occurred and that it will continue.
- Fear under § 46b-16a has subjective and objective components: the applicant must actually fear for personal safety, and that fear must be reasonable under the circumstances.
- Constitutional claims, particularly First Amendment claims, may be deemed abandoned when the appellant does not clearly define, analyze, and support them.
Why It Matters
The decision illustrates that communications need not contain an explicit threat to support a stalking-based protection order. Courts may consider their content, repetition, delivery through personal channels after a request for no contact, and accompanying conduct when deciding whether the applicant reasonably feared for physical safety and whether the conduct was likely to continue.
It also underscores two appellate-practice points: evidentiary relevance depends on the issues and purposes presented to the trial court, and constitutional objections require a clearly identified theory supported by analysis applying governing precedent to the facts.