Connecticut General Statutes

Conn. Gen. Stat. § 47-33c (2025)

Chain of title for not less than forty years creates marketable record title

✓ laws through the 2024 session: the source has not yet published 2025 Public Acts (checked Sept. 2026)
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Any person having the legal capacity to own land in this state, who has an unbroken chain of title to any interest in land for forty years or more, shall be deemed to have a marketable record title to that interest, subject only to the matters stated in section 47-33d. A person has such an unbroken chain of title when the land records of the town in which the land is located disclose a conveyance or other title transaction, of record not less than forty years at the time the marketability is to be determined, which conveyance or other title transaction purports to create such interest in land, or which contains language sufficient to transfer the interest, either in (1) the person claiming that interest, or (2) some other person from whom, by one or more conveyances or other title transactions of record, the purported interest has become vested in the person claiming the interest; with nothing appearing of record, in either case, purporting to divest the claimant of the purported interest.

(1967, P.A. 553, S. 2; 1969, P.A. 509, S. 2; P.A. 78-105, S. 2, 4; P.A. 79-602, S. 43.)

History: 1969 act applied section to cases where unbroken chain of title is at least 40 rather than 60 years; P.A. 78-105 required that conveyance or title transaction contain “language sufficient to transfer the interest”; P.A. 79-602 made minor changes in wording.

Cited. 183 C. 59; 219 C. 81; 239 C. 199. In order to establish marketable record title, a person with the legal capacity of owning land in this state must be able to show an unbroken chain of title to an interest in the land for 40 years or more. 276 C. 782.

Cited. 3 CA 550; 44 CA 683; 46 CA 525.

Cited. 34 CS 31.

Notes of Decisions
Cited in 17 cases (2 in the last 5 years), 1981–2024 · leading case: McBurney v. Cirillo, 889 A.2d 759 (Conn. 2006).
McBurney v. Cirillo, 889 A.2d 759 (Conn. 2006). · cites it 4× “See General Statutes § 47-33c. 23 A person with *808 marketable record title takes the land “free and clear of all interests, claims or charges whatsoever, the existence of which depends upon any act, transaction, event or omission that occurred prior to the effective date of…”
Il Giardino, LLC v. Belle Haven Land Co., 757 A.2d 1103 (Conn. 2000). · cites it 4× “” General Statutes § 47-33c provides: “Chain of title for not less than forty years creates marketable record title.”
Coughlin v. Anderson, 853 A.2d 460 (Conn. 2004). · cites it 3× “General Statutes § 47-33c provides: “Any person having the legal capacity to own land in this state, who has an unbroken chain of title to any interest in land for forty years or more, shall be deemed to have a marketable record title to that interest, subject only to the…”
Mizla v. Depalo, 438 A.2d 820 (Conn. 1981). · cites it 4× “General Statutes § 47-33c. 10 *65 Therefore, if the plaintiff’s root of title of the servient estate is a “conveyance or other title transaction” recorded after the date when the “conveyance or other title transaction” granting the easement in question to the defendants’…”
Simonds v. Shaw, 691 A.2d 1102 (Conn. App. Ct. 1997). · cites it 4× “Ill The defendants argue that the Marketability of Title Act, General Statutes § 47-33b et seq., extinguished the claimed easement.”
Morton v. Syriac, 229 A.3d 1129 (Conn. App. Ct. 2020). · cites it 2× “’’ The trial court thereafter explained that ‘‘[t]he legislature has enacted a bright line test for marketability in the form of General Statutes § 47-33c, which provides that only a ‘person having the legal capacity to own land in this state, who has an unbroken chain of title…”
Dowling v. Heirs of Bond, 282 A.3d 1201 (Conn. 2022). · cites it 2× “A person has such an unbroken chain of title when the land records of the town in which the land is located disclose a conveyance or other title transaction, of record not less than forty years at the time the marketability is to be determined, which conveyance or other title…”
Mierzejewski v. Laneri, 23 A.3d 82 (Conn. App. Ct. 2011). · cites it 3× “The plaintiff also asks us to consider the Marketable Title Act (act); General Statutes § 47-33b et seq.; as an alternate ground of affirmance.”
Vill. Apts., LLC v. Ward, 152 A.3d 76 (Conn. App. Ct. 2016). · cites it 2× “" General Statutes § 47-33c provides: "Any person having the legal capacity to own land in this state, who has an unbroken chain of title to any interest in land for forty years or more, shall be deemed to have a marketable record title to that interest, subject only to the…”
Walters v. Servidio, 320 A.3d 1008 (Conn. App. Ct. 2024). · cites it 2× “Fifty-two (52) and Fifty-three (53) on a certain map entitled ‘Map of Highview Park, North Mianus, Greenwich, Conn’ now on file in the office of the Town Clerk of the Town of Greenwich and therein numbered 353’’ together with ‘‘all right, title and interest in and to the…”
Irving v. Firehouse Assocs., LLC, 898 A.2d 270 (Conn. App. Ct. 2006). · cites it 2× “General Statutes §§ 47-33c and 47-33e. We disagree.”
Christensen v. Reed, 941 A.2d 333 (Conn. App. Ct. 2008). · cites it 2× “General Statutes § 47-33c provides in relevant part that “[a]ny person .”
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