Conn. Gen. Stat. » Title 14 — MOTOR VEHICLES. USE OF THE HIGHWAY BY VEHICLES. GASOLINE · Chapter 246 — Motor Vehicles
Connecticut General Statutes

Conn. Gen. Stat. § 14-51 (2025)

Definitions

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(a) As used in this subpart:

(1) “New car dealer” includes any person, firm or corporation engaged in the business of merchandising new motor vehicles under a manufacturer's or importer's contract for each such make of vehicle who may, incidental to such business, sell used motor vehicles and repair motor vehicles. Such person shall be qualified to conduct such business in accordance with the requirements of section 14-52a.

(2) “Used car dealer” includes any person, firm or corporation engaged in the business of merchandising motor vehicles other than new who may, incidental to such business, repair motor vehicles. A used car dealer does not include any person, firm or corporation engaged in the business of leasing or renting motor vehicles that offers for sale or sells used motor vehicles incidental to its primary business, if (A) such person, firm or corporation is licensed in accordance with the provisions of section 14-15, and (B) the motor vehicles that it offers for sale were formerly the subject of one or more lease agreements to which it was a party and the actual or prospective purchaser is the original lessee pursuant to a purchase option specified in a lease agreement. Such person shall be qualified to conduct such business in accordance with the requirements of section 14-52a.

(3) “Repairer” includes any person, firm or corporation qualified to conduct such business in accordance with the requirements of section 14-52a, having a suitable facility and having adequate equipment, engaged in repairing, overhauling, adjusting, assembling or disassembling any motor vehicle or making minor repairs to any motor vehicle, including repairs and replacement of cooling, electrical, fuel and exhaust systems, brake adjustments, relining and repairs, wheel alignment and balancing and repair and replacement of shock absorbers. “Repairer” does not include a person engaged in making repairs to tires, upholstering, glazing, general blacksmithing, welding and machine work on motor vehicle parts when parts involving such work are disassembled or reassembled by a licensed repairer.

(b) The lubricating of motor vehicles, adding or changing of oil or other motor vehicle fluids, changing of tires and tubes, including the balancing of wheels, or installing of batteries or light bulbs, windshield wiper blades or drive belts shall not be construed as the repairing of motor vehicles under the provisions of this subpart.

(1949 Rev., S. 2391; 1953, 1955, S. 1307d; 1963, P.A. 316; 1967, P.A. 307; P.A. 02-70, S. 21; P.A. 23-40, S. 2.)

History: 1963 act redefined limited repairer to add “relining and repairs,” etc.; 1967 act replaced reference to factory contract with reference to manufacturer's or importer's contract for each make of vehicle in definition of “new car dealer” and deleted references to removing and replacing parts of motor vehicles in definition of “repairer”; (Revisor's note: In 1997 references throughout the general statutes to “Motor Vehicle(s) Commissioner” and “Motor Vehicle(s) Department” were replaced editorially by the Revisors with “Commissioner of Motor Vehicles” or “Department of Motor Vehicles”, as the case may be, for consistency with customary statutory usage); P.A. 02-70 divided existing provisions into Subsecs. (a) and (b) and in Subsec. (a) adding language making definitions applicable to subpart (D), inserting Subdiv. designators and making conforming changes for each definition, in Subdivs. (1) and (2) requiring new car dealer and used car dealer to be qualified to conduct business in accordance with the requirements of Sec. 14-52a and deleting reference to having a suitable and adequate place of business determined to be such by the commissioner, in Subdiv. (2) excluding leasing or renting businesses that sell used motor vehicles incidental to their primary business from the definition of “used car dealer” provided they satisfy criteria in Subparas. (A) and (B), in Subdiv. (3) requiring repairer to be qualified to conduct business in accordance with the requirements of Sec. 14-52a and deleting reference to having a suitable place of business, and in Subsec. (b) specifying the list of services that may be performed without being construed as the repairing of motor vehicle under subpart (D); P.A. 23-40 amended Subsec. (a) by redefining “repairer” in Subdiv. (3) and deleting former Subdiv. (4) re definition of “limited repairer” and made technical changes, effective January 1, 2024.

Zoning appeals board can go no further than apply the test incorporated in statute. 143 C. 634. Cited. 154 C. 540. When variance does not provide automatic extension of nonconforming use. 164 C. 85. Cited. 165 C. 15. Offense charged and offense found were separate and distinct and constituted a taking of plaintiff's property without due process. Id., 42. Commissioner upheld in suspending plaintiff's, repairer's and wrecker's licenses for violation of section and regulations thereunder. 167 C. 304.

Cited. 29 CS 330.

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Notes of Decisions
Cited in 49 cases (1 in the last 5 years), 1967–2022 · leading case: State v. Gardner, 340 S.E.2d 701 (N.C. 1986).
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State v. Gardner, 340 S.E.2d 701 (N.C. 1986). · cites it 4× “C.G.S. §§ 14-51, 14-53, 14-54, 14-55, 14-56, 14-57, and 14-72 in acts which were titled as "clarifications" of the laws.”
Hart Twin Volvo Corp. v. Comm'r of Motor Vehs., 327 A.2d 588 (Conn. 1973). · cites it 7× “This is an appeal from the decision of the defendant commissioner of motor vehicles in finding that the plaintiff violated § 14-51 of the *43 General Statutes regarding the qualifications of a new car dealer and in finding that the plaintiff violated § 14-63-2 (f) of the…”
Nat'l Grange Mut. Ins. v. Santaniello, 961 A.2d 387 (Conn. 2009). · cites it 3× “’ ” It compared the statutory definition of “ ‘[r]epairer’ ” under General Statutes § 14-51 (a) (3), to the definition of “ ‘[u]sed car dealer’ ” under § 14-51 (a) (2), and concluded that “the statutes define ‘used car dealer’ to encompass repair work, but do not define…”
State v. Hannah, 563 S.E.2d 1 (N.C. Ct. App. 2002). · cites it 3× “C.G.S. § 14-51, and assault inflicting serious bodily injury, in violation of N.”
State v. Singletary, 472 S.E.2d 895 (N.C. 1996). · cites it 4× “In defendant's first assignment of error, he contends the trial court committed reversible error in denying his motion to dismiss the burglary charge against him because "the uncontradicted evidence showed that the dwelling which defendant entered was his own residence."…”
Blumenthal v. Barnes, 804 A.2d 152 (Conn. 2002). · cites it 2× “ommuter income tax); General Statutes § 3-130 (authorizing attorney general to institute legal proceedings against common carriers to obtain reasonable rates when directed by governor); General Statutes § 14-65k (b) (attorney general, at request of commissioner of motor…”
State v. Thomas, 514 S.E.2d 486 (N.C. 1999). · cites it 2× “Once again, we find no merit to defendant’s contention. The indictment for burglary alleged that defendant did unlawfully and feloniously break and enter the dwelling of the victim in the nighttime with the intent to commit a felony, larceny, or robbery therein.”
State v. Lucas, 548 S.E.2d 712 (N.C. 2001). “C.G.S. § 14-51 (1999); State v. Singletary, 344 N.”
Small v. Going Forward, Inc., 915 A.2d 298 (Conn. 2007). · cites it 2× “of the premises to determine the accuracy of such records; or (4) has made a false statement as to the condition, prior ownership or prior use of any motor vehicle sold, exchanged, transferred, offered for sale or repaired if the licensee knew or should have known that such…”
State v. Montgomery, 417 S.E.2d 742 (N.C. 1992). · cites it 2× “C.G.S. § 14-51 (1986). Substantial evidence presented by the State tended to show that the defendant broke into or entered the apartment while it was occupied by the victim between 10:30 p.”
State v. Gibbs, 436 S.E.2d 321 (N.C. 1993). “Defendant argues there was substantial evidence showing that when he broke and entered the Farrises’ house, he did not possess the requisite felonious intent.”
State v. Barts, 343 S.E.2d 828 (N.C. 1986). “C.G.S. § 14-51 (1981 and Cum. Supp. 1985); State v.”
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