Argyropoulos v. Argyropoulos - MA Appeals Court Affirms Judgments
Summary
The Massachusetts Appeals Court affirmed modification and contempt judgments from the Probate and Family Court dated April 28, 2025. The husband's appeals failed because he failed to provide an adequate appellate record, omitting the trial transcript, judgment of divorce, contempt complaint, and most trial exhibits. The court held it has no obligation to locate or create an adequate record for a party's benefit, and pro se litigants are held to the same standards as practicing attorneys.
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What changed
The Massachusetts Appeals Court affirmed two judgments from the Probate and Family Court: a modification judgment changing the wife's child support obligation and a contempt judgment finding the wife was not in contempt on three of four alleged violations. The husband's appeals were dismissed because he failed to include critical documents in the record appendix, including the trial transcript, the judgment of divorce, his contempt complaint, trial exhibits, and financial statements.
Parties considering appeals in family court matters should ensure they compile a complete record appendix before filing, as appellate courts will not search for or create records on a party's behalf. Pro se litigants are held to the same standards as attorneys regarding record preservation and appellate procedure.
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Apr 24, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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April 24, 2026 Get Citation Alerts Download PDF Add Note
Camille Marie Ann Argyropoulos v. Leonidas Argyropoulos.
Massachusetts Appeals Court
- Citations: None known
- Docket Number: 25-P-1081
Precedential Status: Non-Precedential
Combined Opinion
NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule
23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28,
as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties
and, therefore, may not fully address the facts of the case or the panel's
decisional rationale. Moreover, such decisions are not circulated to the entire
court and, therefore, represent only the views of the panel that decided the case.
A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25,
2008, may be cited for its persuasive value but, because of the limitations noted
above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260
n.4 (2008).
COMMONWEALTH OF MASSACHUSETTS
APPEALS COURT
25-P-1081
CAMILLE MARIE ANN ARGYROPOULOS1
vs.
LEONIDAS ARGYROPOULOS.
MEMORANDUM AND ORDER PURSUANT TO RULE 23.0
Leonidas Argyropoulos (husband) appeals from portions of a
modification judgment and a contempt judgment issued by a judge
of the Probate and Family Court on April 28, 2025. We affirm.
Following his divorce from Camille Marie Ann Argyropoulos
(wife), the husband filed a complaint for modification and a
complaint for contempt. Represented by counsel, both parties
testified at a consolidated trial on the complaints on March 10,
- On April 28, 2025, after considering the testimony and
fifty exhibits, the judge issued nine pages of factual findings
and a rationale based on "all credible evidence" presented. In
1As is our custom, we set forth the parties' names as they
appear on the joint petition for divorce, notwithstanding that
the wife subsequently changed her surname.
judgments of the same date, the judge modified the wife's child
support obligation and found the wife was not in contempt with
respect to three of the four violations of the judgment of
divorce alleged in the husband's complaint. The husband, now
pro se, appeals from these judgments.
As the appellant, it is the husband's "obligation to
provide an adequate record for review," Smith v. Jones, 67 Mass.
App. Ct. 129, 134 (2006), but he has not done so. He faults the
judge for numerous factual and legal errors and asks us to
vacate the judgments and remand the case "for new findings
consistent with the evidence." He did not, however, include in
the record appendix copies of the trial transcript, the judgment
of divorce, his complaint for contempt, the wife's answers to
the complaints, most of the trial exhibits, and the parties'
February 2023 financial statements filed at the time of the
prior modification judgment, among other things. In the absence
of a complete record "crucial to our review," Cameron v.
Carelli, 39 Mass. App. Ct. 81, 83 (1995), we are rendered unable
to examine the substance of the husband's claims and must affirm
the judgments. It is not an appellate court's obligation to
locate or create an adequate record for the benefit of a party.
See Chokel v. Genzyme Corp., 449 Mass. 272, 279 (2007) ("When a
party fails to include a document in the record appendix, an
appellate court is not required to look beyond that appendix to
2
consider the missing document"). See also Commonwealth v.
Jackson, 419 Mass. 716, 719 (1995) ("pro se litigants are held
to the same standards as practicing members of the bar").
Judgments dated April 28,
2025, affirmed.
By the Court (Meade,
Hodgens & Allen, JJ.2),
Clerk
Entered: April 24, 2026.
2 The panelists are listed in order of seniority.
3
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