Connecticut General Statutes

Conn. Gen. Stat. § 12-182 (2026)

Summary foreclosure of tax liens

✓ current as of May 2026

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Whenever used in sections 12-182 to 12-194, inclusive, “municipality” has the meaning given it in section 12-141 and “tax” includes each property tax or assessment and each installment and part thereof due a municipality, with any interest or other lawful charges incident thereto. In addition to other remedies provided by law, the tax collector of any municipality may bring in its name an action in the nature of an action in rem to foreclose a tax lien or liens on real estate the fair market value of which, in his judgment, is less than the total of the amounts due upon the tax liens and other encumbrances upon the property so liened and is not more than one hundred thousand dollars with respect to any one parcel. No judgment shall be rendered in such proceeding for the recovery of a personal judgment against the owner of the property subject to such lien or liens or any person having an interest therein.

(1949 Rev., S. 1864; P.A. 83-173, S. 1; P.A. 97-320, S. 7, 11; P.A. 02-137, S. 8.)

History: P.A. 83-173 increased limit from $5,000 to $20,000; P.A. 97-320 increased fair market value limit to $50,000, effective July 1, 1997; P.A. 02-137 increased fair market value limit to $100,000.

Cited. 201 C. 1; 236 C. 710.

Cited. 21 CA 275.

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Notes of Decisions

Cited in 5 cases, 1990–1999 · leading case: City of Danbury v. Dana Inv. Corp., 730 A.2d 1128 (Conn. 1999).

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City of Danbury v. Dana Inv. Corp., 730 A.2d 1128 (Conn. 1999). · cites it 3× “to 1993) §§ 12-182 and 12-183 23 indicate that there are certain instances in *25 which a municipality may combine multiple tax lien foreclosures in one civil action.”

Town of Voluntown v. Rytman, 573 A.2d 336 (Conn. App. Ct. 1990). · cites it 2× “See also General Statutes § 49-24. The procedure for the foreclosure of municipal tax liens, like all other liens is governed by General Statutes § 49-25.”

M. Dematteo Constr. Co. v. City of New London, 674 A.2d 845 (Conn. 1996). “wner 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 § 12-193 (reasonable…”

City of Middletown v. Meadows Assocs. of Middletown, Inc., 711 A.2d 1 (Conn. Super. Ct. 1998). · cites it 2× “” 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…”

City of Middletown v. P G Enter. Ltd., No. Cv97-0081557-S (Jul. 13, 1998), 1998 Conn. Super. Ct. 7939 (Conn. Super. Ct. 1998). · cites it 2× “Other methods authorized by the General Statutes include: levy, General Statutes §§ 12-155 through 12-159; tax warrants, General Statutes § 12-135; a collection action, General Statutes § 12-161; and a summary foreclosure not requiring commencement of a judicial proceeding,…”

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