Conn. Gen. Stat. » Title 51 — COURTS · Chapter 882 — Superior Court
Connecticut General Statutes

Conn. Gen. Stat. § 51-164x (2026)

Review of order prohibiting attendance at court session; review of certain orders sealing or limiting disclosure to court documents, affidavits or files

✓ current as of May 2026
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(a) Any person affected by a court order which prohibits any person from attending any session of court, except any session of court conducted pursuant to section 46b-11, 46b-49, 46b-122 or 54-76h or any other provision of the general statutes under which the court is authorized to close proceedings, whether at a pretrial or trial stage, shall have the right to the review of such order by the filing of a petition for review with the Appellate Court within seventy-two hours from the issuance of such court order.

(b) No order subject to review pursuant to subsection (a) of this section shall be effective until seventy-two hours after it has been issued, and the timely filing of any petition for review shall stay the order.

(c) Any person affected by a court order that seals or limits the disclosure of any files, affidavits, documents or other material on file with the court or filed in connection with a court proceeding, except (1) any order issued pursuant to section 46b-11 or 54-33c or any other provision of the general statutes under which the court is authorized to seal or limit the disclosure of files, affidavits, documents or materials, whether at a pretrial or trial stage, and (2) any order issued pursuant to a court rule that seals or limits the disclosure of any affidavit in support of an arrest warrant, shall have the right to the review of such order by the filing of a petition for review with the Appellate Court within seventy-two hours from the issuance of such court order.

(d) The Appellate Court shall provide an expedited hearing on such petitions filed pursuant to subsections (a) and (c) of this section in accordance with such rules as the judges of the Appellate Court may adopt, consistent with the rights of the petitioner and the parties to the case.

(P.A. 80-234, S. 1; P.A. 81-89; June Sp. Sess. P.A. 83-29, S. 39, 82; P.A. 97-178, S. 1.)

History: P.A. 81-89 exempted any session of court conducted pursuant to Sec. 46b-11, 46b-49, 46b-122 or 54-76h or any other provision under which court is authorized to close proceedings, and added provision that petition for review shall be filed within 72 hours from issuance of court order and specified that the appellate session of the superior court shall provide hearing in accordance with rules adopted by judges of the superior court; June Sp. Sess. P.A. 83-29 deleted reference to appellate session of the superior court and added reference to appellate court; P.A. 97-178 amended Subsec. (a) by changing right to “appeal” order to right to “the review of” order, amended Subsec. (b) by changing reference to “such order” to “order subject to review pursuant to subsection (a) of this section” and by requiring “timely” filing of petition, and added Subsec. (c) re review of orders sealing or limiting disclosure of files, affidavits, documents or other material on file with the court and exceptions and amended Subsec. (d), formerly Subsec. (c), re expedited hearing on petitions filed pursuant to Subsecs. (a) and (c).

Cited. 208 C. 365; 222 C. 331; 229 C. 178; 230 C. 441; 233 C. 44; 237 C. 339; 240 C. 623.

Cited. 18 CA 273; 23 CA 433; 26 CA 758; 43 CA 851; 45 CA 142. Section does not provide expedited review of protective order issued pursuant to Sec. 13-5 of the Practice Book. 51 CA 287. Confers jurisdiction for court to review order permitting use of pseudonyms regardless of whether the order is separate or connected to an order sealing a file or any portion thereof; Subsec. (c) provides court with jurisdiction to review a court order that limits disclosure of any material on file; defendants' names are “material on file” and omitting those names and permitting them to be replaced with pseudonyms constitutes limiting their disclosure; whole purpose of statute is to afford expedited review of a court order that limits disclosure, and its express provisions do not contain an exception for nondisclosure of the identity of others. 96 CA 399. Documents at issue are judicial documents that are presumed to be open to the public; respondent waived right to have court seal the documents by disclosing them and by not asking for them to be sealed at time of filing, and trial court's subsequent order allowing disclosure to only certain parties was not proper. 120 CA 837. An order that prevents the media or the public from obtaining copies of documentary or photographic trial exhibits, unless otherwise prohibited from disclosure by an existing order or otherwise applicable law, constitutes a limit on disclosure as contemplated by section and the Practice Book; petitioner had a presumptive right not only to inspect all trial exhibits in custody of clerk's office but to obtain copies of those exhibits. 174 CA 298.

Order for closure too broad where included presentation of evidence on newspaper circulation, prior publicity and publishing policies. 37 CS 627. Cited. Id., 705; 38 CS 546.

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Notes of Decisions
Cited in 72 cases (2 in the last 5 years), 1981–2023 · leading case: State v. Patel, 166 A.3d 727 (Conn. App. Ct. 2017).
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State v. Patel, 166 A.3d 727 (Conn. App. Ct. 2017). · cites it 70× “Finally, to enforce the foregoing limitations upon the court’s power to seal or limit the disclosure of materials on file with the court or filed in connection with a court proceeding, and thus to vindicate the public’s presumptive right of access to such materials, General…”
Bank of New York v. Bell, 993 A.2d 1022 (Conn. App. Ct. 2010). · cites it 28× “[3] The pro se petitioner, Johnathan Bell, alleges in his brief that, by sealing the documents at issue, the court (1) denied him due process by failing to follow the relevant rules of practice, [4] and (2) abused its discretion because (a) the respondent, The Bank of New York,…”
Vargas v. Doe, 900 A.2d 525 (Conn. App. Ct. 2006). · cites it 10× “is governed by statute. ... It is equally axiomatic that, except insofar as the legislature has specifically provided for an interlocutory appeal or other form of interlocutory appellate review; see, e.”
Ostolaza v. Warden, 603 A.2d 768 (Conn. App. Ct. 1992). · cites it 5× “The petitioner's trial counsel also did not object to the court’s action or avail himself of the statutory remedy of an immediate appeal to this court, pursuant to General Statutes § 51-164x. 4 Moreover, this claim was not raised on *769 direct appeal, but was raised for the…”
Doe v. Connecticut Bar Examining Comm., 818 A.2d 14 (Conn. 2003). · cites it 4× “, General Statutes § 52-278l (prejudgment remedies); General Statutes § 54-63g (petition for review of bail); General Statutes § 51-164x (court closure orders); State v.”
Simms v. Warden, 640 A.2d 601 (Conn. 1994). · cites it 2× “To date, the legislature has provided such a remedy only for appeals of orders prohibiting attendance at any session of court; General Statutes § 51-164x (a); and of orders relating to the disclosure of the records of an investigatory grand jury.”
State v. Ayala, 610 A.2d 1162 (Conn. 1992). · cites it 3× “, General Statutes § 51-164x (closure orders); General Statutes § 54-47g (a) (grand jury disclosures).”
State v. Kelly, 545 A.2d 1048 (Conn. 1988). · cites it 3× “A hearing held pursuant to § 54-86f is subject to the provisions of General Statutes § 51-164x which provides that “[a]ny person affected by a court order which prohibits any person from attending any session of court .”
State v. Gault, 39 A.3d 1105 (Conn. 2012). · cites it 4× “Bailey likened the potential appeals by victims to the reviews of court closure orders that certain nonparties may pursue under the authority of General Statutes § 51-164x, [16] and he warned of the much larger number of victims that might seek such appeals were they authorized.”
State v. Sullivan, 712 A.2d 919 (Conn. 1998). · cites it 3× “On motion of either party the court may order such hearing held in camera, subject to the provisions of section 51-164x. If the proceeding is a trial with a jury, such hearing shall be held in the absence of the jury.”
Willow Funding Co., L.P. v. Grencom Assocs., 779 A.2d 174 (Conn. App. Ct. 2001). · cites it 2× “, General Statutes § 52-278l (prejudgment remedies); General Statutes § 54-63g (petition for review of bail); General Statutes § 51-164x (court closure orders); State v.”
Town of New Hartford v. Connecticut Resources Recovery Auth., 970 A.2d 578 (Conn. 2009). · cites it 2× “, General Statutes § 54-63g (petition for review of bail); General Statutes § 51-164x (court closure orders).”
Show all 72 citing cases →
— Conn. Gen. Stat. § 51-164x(a) — 1 case
Hartford Courant Co. v. Pellegrino, 290 F. Supp. 2d 265 (D. Conn. 2003).
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