Conn. Gen. Stat. » Title 47a — LANDLORD AND TENANT · Chapter 833 — Entry and Detainer
Connecticut General Statutes

Conn. Gen. Stat. § 47a-46 (2026)

(Formerly Sec. 52-465). When double damages allowable

✓ current as of May 2026
Find cases: SyfertCases citing this section CT-CGAcga.ct.gov (official) JustiaTitle on Justia CornellLII Search CasesGoogle Scholar
The party aggrieved may recover in a civil action double damages and his costs against the defendant, if it is found on the trial of a complaint brought under section 47a-43 that he entered into the land, tenement or dwelling unit by force or after entry held the same by force or otherwise injured the party aggrieved in the manner described in section 47a-43.

(1949 Rev., S. 8201; P.A. 76-95, S. 22, 27; 76-435, S. 75, 82; P.A. 79-571, S. 42; P.A. 80-483, S. 128, 186.)

History: P.A. 76-95 allowed recovery of double rather than treble damages and authorized recovery of damages in cases where defendant “otherwise injured the party aggrieved in the manner described in section 52-462”; P.A. 76-435 revised effective date section of P.A. 76-95; Sec. 52-465 transferred to Sec. 47a-46 in 1979 and reference to Sec. 52-462 revised to reflect its transfer; P.A. 79-571 added reference to dwelling units and changed wording slightly; P.A. 80-483 made technical changes.

Annotations to former section 52-465:

Action for damages is not defeated by proof of title in defendant. 6 C. 80.

Statute merely provides for damages and costs. 30 CS 607.

Annotations to present section:

Standard of proof required for award of double damages under statute is same as that of other tort cases; judgment of Appellate Court in 24 CA 124 reversed. 221 C. 674.

Cited. 24 CA 124; judgment reversed, see 221 C. 674; 43 CA 1. Trial court did not err in failing to award plaintiffs attorney's fees as a recoverable cost under section; section is devoid of any express language authorizing an award of attorney's fees, court will not presume that legislature intended for statute to operate in derogation of the long-standing common-law rule disfavoring award of attorney's fees to prevailing party. 87 CA 779. Where damages awarded under this section encompass the same conduct as for damages awarded pursuant to Sec. 47a-18a, the sum for actual damages may not be included in the award pursuant to both sections. 89 CA 836.

(Return to Chapter
Table of Contents)		 (Return to
List of Chapters)		 (Return to
List of Titles)

Secs. 47a-47 to 47a-49. Reserved for future use.

(Return to Chapter
Table of Contents)		 (Return to
List of Chapters)		 (Return to
List of Titles)
Notes of Decisions
Cited in 12 cases (1 in the last 5 years), 1991–2024 · leading case: Stuart v. Stuart, 996 A.2d 259 (Conn. 2010).
Sort: Relevance Newest Treatment
Stuart v. Stuart, 996 A.2d 259 (Conn. 2010). · cites it 6× “, 675 (determining whether entitlement to statutory damages under § 47a-46 may be established by preponderance of evidence).”
Rowe v. Goulet, 875 A.2d 564 (Conn. App. Ct. 2005). · cites it 12× “70 in damages and costs as follows: (1) $2483 in statutory damages pursuant to General Statutes § 47a-18a; (2) double damages in the amount of $4966 ($2483 doubled), pursuant to General Statutes § 47a-46; (3) damages for negligent infliction of emotional distress in the amount…”
Freeman v. Alamo Mgmt. Co., 607 A.2d 370 (Conn. 1992). · cites it 11× “The dispositive issue in this appeal is whether, in an action for unlawful entry and detainer under General Statutes § 47a-43 (a) (3), 1 entitlement to an award of statutory punitive damages, pursuant to General Statutes § 47a-46, 2 may be established by a preponderance of the…”
Freeman v. Alamo Mgmt. Co., 586 A.2d 619 (Conn. App. Ct. 1991). · cites it 17× “, the Connecticut Unfair Trade Practices Act (CUTPA), and General Statutes § 47a-46, the entry and detainer act, (4) awarded damages in excess of the valu *126 ations the plaintiff had placed on the same property-in a separate bankruptcy proceeding, and (5) made a de facto award…”
Wilcox v. Ferraina, 920 A.2d 316 (Conn. App. Ct. 2007). · cites it 8× “Thereafter, on June 6, 2005, the plaintiffs filed a request for leave to amend their complaint to include a claim for monetary damages and a request for "double damages" under General Statutes § 47a-46. [4] As the defendants did not file a timely objection to the request, the…”
Stuart v. Stuart, 962 A.2d 842 (Conn. App. Ct. 2009). · cites it 5× “For that reason, in Freeman , the Supreme Court held that this court improperly concluded that entitlement to an award of statutory punitive damages pursuant to General Statutes § 47a-46 required proof by clear and convincing evidence.”
Harty v. Cantor Fitzgerald & Co., 881 A.2d 139 (Conn. 2005). · cites it 2× “2d 370 (1992) (referring to double damages under General Statutes § 47a-46 as “statutory punitive damages”).”
LaFrance v. Lodmell, 144 A.3d 373 (Conn. 2016). · cites it 2× “The defendant sought compensatory damages; treble damages under General Statutes § 52-564 ; double damages under General Statutes § 47a-46 ; treble damages under General Statutes § 52-570b (c) ; punitive damages; indemnification; and attorney's fees.”
Bridgeport Harbour Place I, LLC v. Ganim, 30 A.3d 703 (Conn. App. Ct. 2011). · cites it 2× “79 Freeman , however, is not on point, as the issue there was whether “in an action for unlawful entry and detainer under General Statutes § 47a-43 (a) (3), entitlement to an award of statutory punitive damages, pursuant to General Statutes § 47a-46, may be established by a…”
Town of Branford v. Barbara, 988 A.2d 221 (Conn. 2010). · cites it 2× “2d 370 (1992) (discussing punitive provisions in context of General Statutes § 47a-46). Given the ambiguity of § 52-192a, we must interpret *815 it in favor of the party who would be subject to the punitive consequences of the statute rather than in favor of the party who would…”
LaFrance v. Lodmell (Conn. 2016). · cites it 2× “The defendant sought compensatory damages; treble dam- ages under General Statutes § 52-564; double damages under General Statutes § 47a-46; treble damages under General Statutes § 52-570b (c); punitive damages; indemnification; and attorney’s fees.”
Northland Inv. Corp. v. Pub. Utils. Regulatory Auth. (Dissent) (Conn. 2024). “2024) § 47a-46 then lists the terms that are prohibited in any rental agree- ment.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.