Conn. Gen. Stat. » Title 12 — TAXATION · Chapter 205 — Municipal Tax Liens
Connecticut General Statutes

Conn. Gen. Stat. § 12-181 (2026)

Foreclosure of tax liens

✓ current as of May 2026
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Whenever used in this section, unless the context otherwise requires, “municipality” has the meaning given thereto in section 12-141. The tax collector of any municipality may bring suit for the foreclosure of tax liens in the name of the municipality by which the tax was laid, and all municipalities having tax liens upon the same piece of real estate may join in one complaint for the foreclosure of the same, in which case the amount of the largest unpaid tax shall determine the jurisdiction of the court. If all municipalities having tax liens upon the same piece of real estate do not join in a foreclosure action, any party to such action may petition the court to cite in any or all of such municipalities as may be omitted, and the court shall order such municipality or municipalities to appear in such action and be joined in one complaint. The court in which action is commenced shall continue to have jurisdiction thereof and may dispose of such action in the same manner as if all the municipalities had commenced action by joining in one complaint. If one or more municipalities having one or more tax liens upon the same piece of property are not joined in one action, each of such municipalities shall have the right to petition the court to be made a party plaintiff to such action and have its claims determined in the same action, in which case the same court shall continue to have jurisdiction of the action and shall have the same rights to dispose of such action as if all municipalities had originally joined in the complaint. The court having jurisdiction under the provisions of this section may limit the time for redemption, order the sale of the real estate, determine the relative amount of the undivided interest of each municipality in real estate obtained by absolute foreclosure if two or more municipalities are parties to one foreclosure action or pass such other decree as it judges to be equitable. If one or more municipalities foreclose one or more tax liens on real estate and acquire absolute title thereto and if any other municipality having one or more tax liens upon such real estate at the time such foreclosure title becomes absolute has not, either as plaintiff or defendant, been made a party thereto, the tax liens of each of such other municipalities shall not be thereby invalidated or jeopardized.

(1949 Rev., S. 1863.)

Effect of foreclosure. 74 C. 683. One paying tax not subrogated to right to foreclose. 75 C. 372. Court may apply partial payments. 76 C. 699. Cited. 128 C. 552; 201 C. 1; 225 C. 211; 236 C. 710. Deficiency judgment provisions of Sec. 49-14 do not apply to tax lien foreclosure actions brought pursuant to this section. 255 C. 379.

Cited. 4 CA 460; 21 CA 275. Although section may preclude invalidation of tax liens, it does not deprive court of subject matter jurisdiction over the cause of action. 61 CA 481.

Cited. 4 CS 391. Statute is a municipal empowerment statute, not a statutory cause of action. 45 CS 435.

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Notes of Decisions
Cited in 22 cases (2 in the last 5 years), 1985–2022 · leading case: Town of Winchester v. Nw. Assocs., 767 A.2d 687 (Conn. 2001).
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Town of Winchester v. Nw. Assocs., 767 A.2d 687 (Conn. 2001). · cites it 11× “The sole issue presented by this appeal is whether a municipality that has foreclosed upon tax hens pursuant to General Statutes § 12-181 1 is entitled *381 to a deficiency judgment under General Statutes § 49-14.”
Town of Voluntown v. Rytman, 573 A.2d 336 (Conn. App. Ct. 1990). · cites it 4× “The plaintiff town of Voluntown instituted this action pursuant to General Statutes § 12-181 against the named defendant, Julius Rytman, 1 for the foreclosure of municipal tax liens owed on a poultry farm for the tax lists 1984 through 1986.”
Town of Brookfield v. Candlewood Shores Estates, Inc., 513 A.2d 1218 (Conn. 1986). · cites it 3× “General Statutes §§ 12-181 and 12-182 (foreclosure of municipal tax liens).”
City of Danbury v. Dana Inv. Corp., 730 A.2d 1128 (Conn. 1999). · cites it 3× “to 1987) § 12-193 was amended by adding the second clause, namely, “and may be collected by the municipality once a foreclosure action has been brought pursuant to section 12-181 or 12-182.” Public Acts 1988, No.”
Redding v. Georgetown Land Dev. Co., LLC, 337 Conn. 75 (Conn. 2020). · cites it 5× “If all municipalities having tax liens upon the same piece of real estate do not join in a foreclosure action, any party to such action may petition the court to cite in any or all of such municipalities as may be omitted, and the court shall order such municipality or…”
Ledyard v. WMS Gaming, Inc., 338 Conn. 687 (Conn. 2021). · cites it 2× “s, and reasonable attorney’s fees incurred by a municipality as a result of any foreclosure action brought pursuant to section 12-181 or 12-182 and directly related thereto shall be taxed in any such proceeding against any person or persons having title to any property so…”
City of Hartford v. Pan Pac. Dev. (Connecticut), Inc., 764 A.2d 1273 (Conn. App. Ct. 2001). · cites it 4× “The tax collector of any municipality may bring suit for the foreclosure of tax hens in the name of the municipality by which the tax was laid, and all municipalities having tax hens upon the same piece of real estate may join in one complaint for the foreclosure of the same, in…”
M. Dematteo Constr. Co. v. City of New London, 674 A.2d 845 (Conn. 1996). · cites it 2× “court shall award property owner reasonable appraisal fees); General Statutes § 12-161a (in proceedings by municipality to collect delinquent taxes on personal property, the owner of the property shall pay reasonable appraiser’s fees incurred by municipality); General Statutes §…”
Town of Glastonbury v. Sakon, 194 A.3d 1277 (Conn. App. Ct. 2018). · cites it 2× “See also Practice Book § 10-70 (setting forth elements municipality must allege and prove in tax lien foreclosure action).”
City of Danbury v. Dana Inv. Corp., 776 A.2d 438 (Conn. 2001). · cites it 2× “General Statutes § 12-193 provides: “Court costs, reasonable appraiser’s fees, and reasonable attorney’s fees incurred by a municipality as a result of any foreclosure action brought pursuant to section 12-181 or 12-182 and directly related thereto shall be taxed in any such…”
City of Middletown v. Meadows Assocs. of Middletown, Inc., 711 A.2d 1 (Conn. Super. Ct. 1998). · cites it 3× “” The procedures and notice requirements for foreclosure of individual tax liens (as opposed to summary foreclosure of a list of hens collectively, as provided in General Statutes § 12-182) are not specified in General Statutes § 12-181, which is entitled “Foreclosure of tax…”
Town of Branford v. Monaco, 709 A.2d 582 (Conn. App. Ct. 1998). · cites it 2× “In April, 1996, the plaintiff commenced the present action to foreclose municipal tax hens on the subject property pursuant to General Statutes § 12-181. On *219 December 9, 1996, the defendants filed an answer and two special defenses.”
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