In any civil action to recover damages resulting from personal injury, wrongful death or damage to property, the trier of fact may award double or treble damages if the injured party has specifically pleaded that another party has deliberately or with reckless disregard operated a motor vehicle in violation of section
14-218a,
14-219,
14-222,
14-227a or
14-227m, subdivision (1) or (2) of subsection (a) of section
14-227n or section
14-230,
14-234,
14-237,
14-239,
14-240a or
14-296aa, and that such violation was a substantial factor in causing such injury, death or damage to property. The owner of a rental or leased motor vehicle shall not be responsible for such damages unless the damages arose from such owner's operation of the motor vehicle.
(1949 Rev., S. 2492; P.A. 76-435, S. 1, 82; P.A. 77-604, S. 7, 84; P.A. 85-122; P.A. 88-229; P.A. 03-250, S. 2; P.A. 16-126, S. 22; P.A. 19-160, S. 1.)
History: P.A. 76-435 deleted references to repealed Secs. 14-246 and 14-293; P.A. 77-604 replaced reference to Sec. 14-232 with reference to Sec. 14-242; P.A. 85-122 made provisions of section inapplicable to person licensed under Sec. 14-15; P.A. 88-229 entirely replaced prior provisions re the liability for double or treble damages of each person who, by neglecting to conform to any provision of Secs. 14-230 to 14-242, inclusive, or Sec. 14-245 or 14-247, causes injury to the person or property of another if the court, in its discretion, determines that double or treble damages are just with provisions authorizing the trier of fact to award double or treble damages if the injured party has specifically pleaded that another party has deliberately or with reckless disregard operated a motor vehicle in violation of certain enumerated statutes and that such violation was a substantial factor in causing the injury, death or damage to property; P.A. 03-250 provided that the owner of a rental or leased motor vehicle is not responsible for damages unless the damages arose from such owner's operation of the motor vehicle, effective October 1, 2003, and applicable to causes of action accruing on or after that date; P.A. 16-126 added references to Secs. 14-227m and 14-227n(a)(1) and (2); P.A. 19-160 added reference to Sec. 14-296aa, effective July 1, 2019, and applicable to any civil action pending on or filed on or after said date.
Treble damages were originally mandatory and were made discretionary in 1909; the jury should find the actual damages and the court multiply them. 59 C. 1. Statute is to be strictly construed; multiple damages cannot be awarded if the complaint omits any element of statute; 66 C. 570; 75 C. 124; or alleges other tortious acts, so that the verdict does not necessarily establish violation of statute. 59 C. 1; 84 C. 52; 87 C. 256. Multiple damages should be claimed in the demand for relief. 84 C. 52; 87 C. 257. Cited. 111 C. 729. Additional damages are penal and are not recoverable from insurer. 127 C. 533. Cited. 134 C. 599; 192 C. 280; Id., 301; 196 C. 494; 203 C. 667. Unconstitutionally deprives defendant of jury trial; statute does not purport to authorize jury determination of multiple damages. 206 C. 608. Cited. 211 C. 133; 216 C. 40.
Judicially created standard precludes unlimited and arbitrary discretion by the court in its application of statute. 4 CA 451. Cited. 8 CA 254; 31 CA 781; 43 CA 1.
Cited. 39 CS 228.
Double or treble damages may be claimed in complaint alleging both common-law and statutory negligence, provided facts which bring case within statute are clearly stated. 4 Conn. Cir. Ct. 462–464.
Notes of Decisions
Cited in
36
cases (
5 in the last 5 years), 1961–2024 · leading case:
Bishop v. Kelly, 539 A.2d 108 (Conn. 1988).
Bishop v. Kelly, 539 A.2d 108 (Conn. 1988).
· cites it 37× “The dispositive issue in this appeal is whether General Statutes § 14-295, 1 which allows a trial *610 court to double or treble the damages awarded by a jury in tort actions involving violations of the rules of the road, infringes the right to trial by jury under the…”
Gionfriddo v. Avis Rent A Car Sys., Inc., 472 A.2d 306 (Conn. 1984).
· cites it 16× “The complaint sought: in the first count, compensatory damages; in the second count, exemplary damages; and in the third count, double or treble damages pursuant to General Statutes § 14-295. 1 The plaintiff successfully moved for summary judgment as to liability against all…”
Jack v. Scanlon, 495 A.2d 1084 (Conn. App. Ct. 1985).
· cites it 24× “This appeal raises as its principal issues the propriety and constitutionality of an award of double damages pursuant to General Statutes § 14-295. The case arose from the following facts: The plaintiff was southbound on a highway divided by a median strip.”
Gothberg v. Town of Plainville, 148 F. Supp. 3d 168 (D. Conn. 2015).
· cites it 9× “7, 2006), a case on which the Southington Defendants rely, the court concluded that a private cause of action based on Conn. Gen. Stat. § 14-295 was overwhelmingly penal in nature and thus not precluded by § 52-599(e)(3).”
Matthiessen v. Vanech, 836 A.2d 394 (Conn. 2003).
· cites it 4× “5 *827 The jury declined to award double or treble damages as permitted by General Statutes § 14-295. 6 Additional facts will be provided as necessary.”
Bebry v. Zanauskas, 841 A.2d 282 (Conn. App. Ct. 2004).
· cites it 9× “ntiffs claim that the trial court improperly (1) held that the defendants did not owe a duty to the plaintiffs arising from the defendants’ ability to control Joseph Zanauskas’ behavior and their knowledge of his prior incidents of operating a motor vehicle while intoxicated,…”
Ford v. Blue Cross & Blue Shield of Connecticut, Inc., 578 A.2d 1054 (Conn. 1990).
· cites it 4× “to 1987) § 14-295, entrusting the award of double or treble jury awards in certain tort actions to the court, violated the defendant’s right to trial by jury as guaranteed by our state constitution.”
Harty v. Cantor Fitzgerald & Co., 881 A.2d 139 (Conn. 2005).
· cites it 3× “2d 688 (1993), concluding that an insurance policy exclusion for punitive and exemplary damages did not encompass statutory multiple damages under General Statutes § 14-295, which provides for double or treble damages for personal injury, wrongful death or property damage…”
Ghimbasan v. S & H EXPRESS, INC., 814 F. Supp. 2d 120 (D. Conn. 2011).
· cites it 40× “Plaintiffs’ allegations include claims of statutory negligence pursuant to Conn. Gen. Stat. § 14-295 against Rice (Count Three) asserting that Rice caused an accident by recklessly stopping his vehicle in the center of the highway following a prior collision, and a derivative…”
Harewood v. Carter, 772 A.2d 764 (Conn. App. Ct. 2001).
· cites it 7× “The first issue to be decided in this case, which arises out of a motor vehicle accident, is whether the trial court improperly granted the defendant’s motion for a directed verdict on count two of the plaintiffs complaint, which alleged a violation of General Statutes §§…”
Robinson v. Gailno, 880 A.2d 127 (Conn. 2005).
· cites it 4× “4 Thereafter, the plaintiff brought this action to recover both economic and noneconomic damages, claiming that she was entitled, inter alia, to compensatory and double and treble damages pursuant to General Statutes § 14-295, 5 for injuries caused by the defendant’s allegedly…”
Tomick v. United Parcel Serv., Inc., 153 A.3d 615 (Conn. 2016).
· cites it 2× “2d 466 (insurance **503 policy exclusion for punitive and exemplary damages did not encompass statutory multiple damages under General Statutes § 14-295 for injuries, death or property damage arising from enumerated traffic violations), cert.”
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