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Argyropoulos v. Argyropoulos - MA Appeals Court Affirms Judgments

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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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GovPing monitors Massachusetts Appeals Court for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 91 changes logged to date.

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.

Archived snapshot

Apr 24, 2026

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April 24, 2026 Get Citation Alerts Download PDF Add Note

Camille Marie Ann Argyropoulos v. Leonidas Argyropoulos.

Massachusetts Appeals Court

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,

  1. 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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Last updated

Classification

Agency
MA Appeals Court
Filed
April 24th, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Minor
Docket
25-P-1081

Who this affects

Applies to
Courts Criminal defendants
Industry sector
9211 Government & Public Administration
Activity scope
Divorce proceedings Child support Contempt actions
Geographic scope
Massachusetts US-MA

Taxonomy

Primary area
Family Law
Operational domain
Legal
Topics
Judicial Administration

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