Conn. Gen. Stat. » Title 02 — GENERAL ASSEMBLY AND LEGISLATIVE AGENCIES · Chapter 16 — General Assembly
Connecticut General Statutes

Conn. Gen. Stat. § 2-45 (2025)

Legislative appearances

✓ laws through the 2024 session: the source has not yet published 2025 Public Acts (checked Sept. 2026)
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Section 2-45 is repealed.

(1949 Rev., S. 40; 1955, S. 14d; 1969, P.A. 197; P.A. 75-272; P.A. 77-605, S. 20, 21.)

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Notes of Decisions
Cited in 14 cases (5 in the last 5 years), 1973–2025 · leading case: Burton v. Mottolese, 835 A.2d 998 (Conn. 2003).
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Burton v. Mottolese, 835 A.2d 998 (Conn. 2003). · cites it 2× “Moreover, Practice Book § 2-45 35 provides in *29 relevant part that “[without limiting the inherent powers of the court, if attorney misconduct occurs in the actual presence of the court, the statewide grievance committee and the grievance panels shall defer to the court if the…”
Moffett v. Killian, 360 F. Supp. 228 (D. Conn. 1973). · cites it 13× “§ 2-45. 1 Jurisdiction is based upon 42 U.”
Ambrose v. Ambrose, 309 A.3d 305 (Conn. App. Ct. 2024). · cites it 2× “Indeed, for matters relating to courtroom conduct, judges have primary jurisdiction over lawyers who do not meet their obligations as officers of the court.”
Chief Disciplinary Couns. v. Rozbicki, 167 A.3d 351 (Conn. 2017). “Citing Practice Book § 2-45, the Appellate Court explained that "[w]hen the misconduct occurs in the actual presence of the court, the [Statewide Grievance Committee] shall defer .”
Disciplinary Couns. v. Williams, 142 A.3d 391 (Conn. App. Ct. 2016). · cites it 2× “The court further explained to Williams that, at that hearing, Williams would be permitted to present his argument to the court that demonstrated that he did not wilfully violate the court's order. Specifically, the court told Williams during the October 1, 2014 proceedings that…”
In re Williams, 978 F. Supp. 2d 123 (D. Conn. 2012). · cites it 3× “Respondent moved to quash the order on the ground that the alleged misconduct had not occurred in the presence of Judge Foley as required to permit the court to proceed summarily under Practice Book § 2-45, rather than by filing a written complaint with the statewide bar counsel.”
Rules Comm. v. Freedom of Info. Comm'n, 472 A.2d 9 (Conn. 1984). “No member of the public shall be required, as a condition to attendance at a meeting of any such body, to register his name, or furnish other information, or complete a questionnaire or otherwise fulfill any condition precedent to his attendance, except as provided in section…”
Ansell v. Statewide Grievance Comm., 865 A.2d 1215 (Conn. App. Ct. 2005). “) Practice Book § 2-45. Although Ansell’s conduct occurred before the Superior Court, the courts did not choose to exercise their inherent authority, and neither the trial court nor we can properly infer from the courts’ silence a determination of no misconduct.”
In re Cunha, 330 A.3d 181 (Conn. App. Ct. 2025). · cites it 5× “Held: Contrary to the respondent’s claim that, because the underlying disciplinary proceedings against her were initiated pursuant to statute (§ 51-84) and the rule of practice (§ 2-45), the trial court’s jurisdiction was exclusively limited to determining what discipline should…”
In re Cunha, 330 A.3d 181 (Conn. App. Ct. 2025). · cites it 5× “Held: Contrary to the respondent’s claim that, because the underlying disciplinary proceedings against her were initiated pursuant to statute (§ 51-84) and the rule of practice (§ 2-45), the trial court’s jurisdiction was exclusively limited to determining what discipline should…”
Lafferty v. Jones, 316 A.3d 742 (Conn. App. Ct. 2024). · cites it 4× “’’ (Footnote added.) Lafferty v. Jones, 220 Conn. App.”
Lafferty v. Jones, 316 A.3d 742 (Conn. App. Ct. 2024). · cites it 4× “Without limiting the inherent powers of the court, if attorney misconduct occurs in the actual presence of the court, the Statewide Grievance Committee and the grievance panels shall defer to the court if the court chooses to exercise its jurisdiction.”
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