Connecticut General Statutes

Conn. Gen. Stat. § 47-33a (2026)

Action on agreement to sell real estate

✓ current as of May 2026

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(a) No interest in real property existing under an executory agreement for the sale of real property or for the sale of an interest in real property or under an option to purchase real property shall survive longer than one year after the date provided in the agreement for the performance of it or, if the date is not so provided, longer than eighteen months after the date on which the agreement was executed, unless the interest is extended as provided herein or unless action is commenced within the period to enforce the agreement and notice of lis pendens is filed as directed by section 52-325.

(b) The interest may be extended only by reexecution of the written agreement or by execution of a new written agreement, provided the agreement, whether reexecuted or newly executed, shall be recorded as directed by sections 47-10 and 47-17. The period provided by this section shall not otherwise be extended, whether because of death, disability or absence from the state or for any other reason. Upon the expiration of an interest the title to property affected by the interest shall not thereafter be considered unmarketable because of the expired interest.

(c) Nothing in this section shall be construed to limit or deny any legal or equitable rights a party may have under the agreement except the right to have the agreement specifically enforced.

(1959, P.A. 550; February, 1965, P.A. 401, S. 1; P.A. 79-602, S. 125.)

History: 1965 act applied Subsec. (a) provisions to options to purchase real property; P.A. 79-602 substituted “the” for “such” and “of it” for “thereof”.

Cited. 174 C. 592; 206 C. 454; 213 C. 676; 216 C. 509; 220 C. 453.

Cited. 6 CA 595; 18 CA 569; 19 CA 413; 23 CA 579; 40 CA 64; 45 CA 466.

Cited. 3 Conn. Cir. Ct. 86.

Subsec. (a):

Option to purchase contained in commercial lease which must be exercised within leasehold term valid without regard to rule against perpetuities. 213 C. 676.

Death of grantor is a specific event that may act as the operative date where no date for exercising an option is otherwise provided. 57 CA 636. “Interest” is plaintiff's ability to purchase the property and seek specific performance once the option has been exercised. 100 CA 155.

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Notes of Decisions

Cited in 18 cases, 1964–2013 · leading case: Nash v. Stevens, 71 A.3d 635 (Conn. App. Ct. 2013).

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Nash v. Stevens, 71 A.3d 635 (Conn. App. Ct. 2013). · cites it 70× “1 On appeal, the plaintiff claims that the trial court improperly granted the defendants’ motions for summary judgment as a result of (1) its misapplication of General Statutes § 47-33a and (2) its failure to consider the intent of the parties in its analysis of § 47-33a.”

Celentano v. Oaks Condo. Ass'n, 830 A.2d 164 (Conn. 2003). · cites it 9× “their appeal, the defendants claim that the trial court improperly concluded that: (1) the Oaks was a legally created condominium pursuant to the condominium act; (2) the ground lease was not presumptively unconscionable pursuant to § 47-210; and (3) the defendants were not…”

Texaco Refining & Mktg., Inc. v. Samowitz, 570 A.2d 170 (Conn. 1990). · cites it 24× “This appeal concerns the validity, under General Statutes § 47-33a and the common law rule against perpetuities, of an option to purchase real property contained in a long-term commercial lease.”

Battalino v. Van Patten, 917 A.2d 595 (Conn. App. Ct. 2007). · cites it 16× “8 The defendant did not raise General Statutes § 47-33a as a special defense in his pleadings but raised it as a defense in his final argument to the trial court.”

United States v. 74.05 Acres of Land, 428 F. Supp. 2d 57 (D. Conn. 2006). · cites it 15× “The Claimant also contends that by filing a Verified Claim/Statement of Interest or Right and an Answer and Affirmative Defenses to Plaintiffs Verified Complaint of *61 Forfeiture, it commenced an action within the meaning of Conn. Gen.Stat. § 47-33a and thereby preserved its…”

McNeil v. Riccio, 696 A.2d 1050 (Conn. App. Ct. 1997). · cites it 7× “The plaintiffs’ claim for specific performance based on either of the 1975 contracts was at least twelve years late and, therefore, barred by General Statutes § 47-33a (c). 1 Finally, the trial court found that certain maintenance and improvements paid for by the plain *469…”

Christophersen v. Blount, 582 A.2d 460 (Conn. 1990). · cites it 6× “After a hearing, the trial court rendered judgment for the defendants concluding that: (1) the plaintiff had delayed an unreasonable amount of time in filing the subdivision application; (2) the contract failed to comply with General Statutes § 52-550, 1 the statute of frauds;…”

Booth v. Flanagan, 562 A.2d 592 (Conn. App. Ct. 1989). · cites it 11× “The defendants had raised numerous special defenses, among them that the court lacked subject matter jurisdiction based on General Statutes § 47-33a. 1 The trial court, Berdon, J.”

Funaro v. Baisley, 749 A.2d 1205 (Conn. App. Ct. 2000). · cites it 11× “The defendant claims that the court improperly (1) misconstrued General Statutes § 47-33a and (2) found that the plaintiff, Joan Funaro, was not required to perform fully the terms of the option agreement, specifically, the tender of a promissory note and mortgage deed.”

Sink v. Meadow Wood Country Estates, Inc., 559 A.2d 725 (Conn. App. Ct. 1989). · cites it 10× “Specifically, the defendant challenges the trial court’s handling of two defenses, namely, (1) the provision in General Statutes § 47-33a (b) 5 that an agreement to extend the closing date of a contract for the sale of real estate beyond one year from the *580 date of the…”

Morris v. Costa, 392 A.2d 468 (Conn. 1978). · cites it 4× “The conclusions attacked are that the defendant Angelo Costa breached the agree *597 ment of sale by not closing as agreed on September 30, 1961, that the contract which was the agreement of sale was a contract under seal, that the plaintiffs’ claim for specific performance was…”

Bolmer v. Kocet, 507 A.2d 129 (Conn. App. Ct. 1986). · cites it 4× “The first was that specific performance was barred by General Statutes § 47-33a. 2 The second asserted that Mary Kocet had, pursuant to the contract, elected to declare the contract void because the planning and zoning commission had disapproved the minimum eight lot subdi *603…”

Show all 18 citing cases →

— Conn. Gen. Stat. § 47-33a(a) — 1 case

United States v. 74.05 Acres of Land, 428 F. Supp. 2d 57 (D. Conn. 2006). “The Claimant also contends that by filing a Verified Claim/Statement of Interest or Right and an Answer and Affirmative Defenses to Plaintiffs Verified Complaint of *61 Forfeiture, it commenced an action within the meaning of Conn. Gen.Stat. § 47-33a and thereby preserved its…”

— Conn. Gen. Stat. § 47-33a(b) — 2 cases

Nash v. Stevens, 71 A.3d 635 (Conn. App. Ct. 2013). “1 On appeal, the plaintiff claims that the trial court improperly granted the defendants’ motions for summary judgment as a result of (1) its misapplication of General Statutes § 47-33a and (2) its failure to consider the intent of the parties in its analysis of § 47-33a.”

— Conn. Gen. Stat. § 47-33a(c) — 1 case

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