Membrino v. Membrino

── Membrino v. Membrino ── Court: Connecticut Appellate Court Date: June 02, 2026 Author: Alvord Category: General ************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************  Membrino v. Membrino CONRAD O. MEMBRINO v. RALPH G. MEMBRINO ET AL. (AC 48017) Alvord, Elgo and Keller, Js. Syllabus The plaintiff appealed from the trial court’s judgment dismissing his com- plaint alleging intentional infliction of emotional distress in connection with proceedings in the Probate Court for lack of subject matter jurisdiction. The plaintiff claimed that the court improperly determined that the allegations asserted in his claim against the defendants were barred by the litigation privilege. Held: The trial court properly determined that it lacked subject matter jurisdic- tion and dismissed the plaintiff’s complaint, as the plaintiff’s claims were predicated on the defendants’ alleged conduct in furtherance of a probate proceeding in which the plaintiff participated and, thus, the specific claim of intentional infliction of emotional distress as alleged by the plaintiff was the type of action the litigation privilege was intended to prevent. Argued December 15, 2025—officially released June 2, 2026 Procedural History Action to recover damages for intentional infliction of emotional distress, and for other relief, brought to the Superior Court in the judicial district of Waterbury, where the plaintiff withdrew his claims as to the defen- dant Eric Somma et al.; thereafter, the court, Massicotte, J., dismissed the action as to the named defendant; sub- sequently, the court, Massicotte, J., rendered judgment dismissing the plaintiff’s complaint, from which the plaintiff appealed to this court. Affirmed. Conrad O. Membrino, self-represented, the appellant (plaintiff). Robert C. Lubus, Jr., with whom was Brooke Weise, for the appellees (defendant Roberta Minuto et al.). Opinion ALVORD, J. This appeal concerns a civil action that was commenced in 2017 and arose out of a probate mat- ter originating in 2012. The self-represented plaintiff,  Membrino v. Membrino Conrad O. Membrino, appeals from the judgment of the trial court dismissing his complaint, alleging intentional infliction of emotional distress, against the defendants Roberta Minuto (Roberta) and Alda Membrino (Alda).1 On appeal, the plaintiff claims that the court improperly dismissed his action for lack of subject matter jurisdic- tion on the ground that the allegations asserted in his intentional infliction of emotional distress claim were barred by the litigat