Connecticut General Statutes

Conn. Gen. Stat. § 51-243 (2026)

Alternate jurors in civil cases

✓ current as of May 2026

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(a) In any civil action to be tried to the jury in the Superior Court, if it appears to the court that the trial is likely to be protracted, the court may, in its discretion, direct that, after a jury has been selected, two or more additional jurors shall be added to the jury panel, to be known as “alternate jurors”. Alternate jurors shall have the same qualifications and be selected and subject to examination and challenge in the same manner and to the same extent as the jurors constituting the regular panel. In any case when the court directs the selection of alternate jurors, each party may peremptorily challenge four jurors. Where the court determines a unity of interest exists, several plaintiffs or several defendants may be considered as a single party for the purpose of making challenges, or the court may allow additional peremptory challenges and permit them to be exercised separately or jointly. For the purposes of this subsection, a “unity of interest” means that the interests of the several plaintiffs or of the several defendants are substantially similar. A unity of interest shall be found to exist among parties who are represented by the same attorney or law firm. In addition, there shall be a presumption that a unity of interest exists among parties where no cross claims or apportionment complaints have been filed against one another. In all civil actions, the total number of peremptory challenges allowed to the plaintiff or plaintiffs shall not exceed twice the number of peremptory challenges allowed to the defendant or defendants, and the total number of peremptory challenges allowed to the defendant or defendants shall not exceed twice the number of peremptory challenges allowed to the plaintiff or plaintiffs.

(b) Alternate jurors shall be sworn separately from those constituting the regular panel, and the oaths to be administered shall be as provided in section 1-25.

(c) Alternate jurors shall attend at all times upon trial of the action. They shall be seated when the case is on trial with or near the jurors constituting the regular panel, with equal opportunity to see and hear all matters adduced in the trial.

(d) If, at any time, any juror shall, for any reason, become unable to further perform his or her duty, the court may excuse such juror. If any juror is so excused or dies, the court may order that an alternate juror who is designated by lot to be drawn by the clerk, shall become a part of the regular panel and the trial shall then proceed as though the alternate juror had been a member of the regular panel from the time when the trial was begun. If a juror becomes a member of the regular panel after deliberations have begun, the jury shall be instructed by the court that deliberations by the jury shall begin anew.

(e) A juror selected to serve as an alternate shall not be segregated from the regular panel except when the case is given to the regular panel for deliberation at which time such alternate juror shall be dismissed from further service on the case or may remain in service under the direction of the court.

(1949 Rev., S. 7911; 1953, S. 3163d; March, 1958, P.A. 27, S. 40; 1959, P.A. 28, S. 211; 1969, P.A. 518; 1971, P.A. 40, S. 3; P.A. 73-576, S. 2, 4; P.A. 74-183, S. 56, 291; P.A. 76-336, S. 17; 76-436, S. 106, 681; P.A. 77-452, S. 20, 72; P.A. 80-313, S. 56; P.A. 82-248, S. 130; 82-307, S. 4, 8; P.A. 93-176, S. 2; P.A. 01-152, S. 2; P.A. 12-133, S. 16.)

History: 1959 act included circuit court; 1969 act amended Subsec. (c) to delete provision which had forbidden alternate jurors to counsel or confer with jurors on regular panel concerning trial matters unless they become part of regular panel, to allow substitution of alternate juror for juror at any time rather than “before the case is committed to the jury” and to add provision forbidding segregation of alternates from regular panel except during deliberation at which time alternates are dismissed from service; 1971 act amended provision re challenges in civil actions to allow four challenges in all cases where previously five challenges were allowed where trial was to twelve-person jury and four where trial was to six-person jury and substituted “Connecticut Correctional Institution, Somers” for “State Prison”; P.A. 73-576 amended provision re challenges in Subsec. (a) to allow eight challenges in all cases where offense is punishable by imprisonment for less than life where previously ten challenges were allowed in such cases tried to twelve-person jury and eight in cases tried to six-person jury and to allow four challenges in all other cases where previously five challenges were allowed in cases tried to twelve-person jury and four in cases tried to six-person jury, effective June 12, 1973, and applicable to all prosecutions claimed for jury trial on and after that date; P.A. 74-183 removed circuit court trials from purview of section, reflecting transfer of its functions to court of common pleas, effective December 31, 1974; P.A. 76-336 specified that eight challenges allowed where imprisonment is “for more than one year”; P.A. 76-436 deleted specific reference to Somers Correctional Institution in Subsec. (a), effective July 1, 1978; P.A. 77-452 made technical correction in Subsec. (a); P.A. 80-313 removed criminal prosecutions from purview of section and deleted provision re number of challenges allowed in certain categories of criminal prosecutions; P.A. 82-248 rephrased the section and redesignated parts of former Subsec. (c) as new Subsecs. (d) and (e); P.A. 82-307 amended Subsec. (a) by changing the number of alternate jurors from “one or two” to two “or more” and amended Subsec. (c) to reflect this change; P.A. 93-176 amended Subsec. (a) to add provision re peremptory challenges when the court determines a unity of interest exists and define “unity of interest”; P.A. 01-152 amended Subsec. (a) to add provisions that a unity of interest shall be found to exist among parties represented by the same attorney or law firm, that there shall be a presumption that a unity of interest exists among parties where no cross complaints or apportionment complaints have been filed and that the total number of peremptory challenges allowed to one side shall not exceed twice the number allowed to the other side; P.A. 12-133 amended Subsec. (d) by adding provision re jury instruction if juror becomes a member of the regular panel after deliberations have begun, amended Subsec. (e) by adding provision re alternate juror may remain in service when case is given to regular panel for deliberation, and made technical changes.

See Sec. 54-82h re alternate jurors in criminal prosecutions.

Cited. 144 C. 295; 182 C. 419; 186 C. 632; 187 C. 73; 191 C. 62. Single party has no legal entitlement to multiple sets of challenges when distinct causes of action have been consolidated; the granting of more challenges than provided by law is subject to review for abuse of discretion; in conducting appellate review, court must consider whether granting the challenges harmed either party or was inconsistent with an efficient and orderly judicial process. 268 C. 244.

Cited. 17 CA 121; 25 CA 702; 42 CA 542.

Cited. 41 CS 48.

Juror excused from trial in process because of stress and strain resulting from his check problems held valid compliance with statute. 6 Conn. Cir. Ct. 439.

Subsec. (a):

Jury obtained by a party who exercises peremptory challenges not required by law is not a biased jury, but, by allowing such party to exclude jurors suspected of bias or partiality, is a fair and impartial jury. 279 C. 622.

Subsec. does not allow court to grant additional peremptory challenges to only one side in a civil case. 84 CA 656.

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Notes of Decisions

Cited in 15 cases, 1970–2011 · leading case: Carrano v. Yale-New Haven Hosp., 904 A.2d 149 (Conn. 2006).

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Carrano v. Yale-New Haven Hosp., 904 A.2d 149 (Conn. 2006). · cites it 30× “to 2001) § 51-243, [1] the plaintiff [2] was entitled to eight peremptory challenges and the defendants [3] were entitled to twenty because the trial court found that no unity of interest existed among them.”

Kalams v. Giacchetto, 842 A.2d 1100 (Conn. 2004). · cites it 7× “Ill We next consider the plaintiffs claim that the trial court improperly granted eight peremptory challenges to each party instead of four challenges as provided by *257 General Statutes § 51-243. 8 We conclude that the trial court improperly determined that each party was…”

State v. Murray, 757 A.2d 578 (Conn. 2000). · cites it 8× “In 1959, the alternate juror statute, General Statutes § 51-243, allowed the substitution of an alternate if, “at any time,” a regular juror became unable to fulfill his or her official duties.”

State v. McCall, 444 A.2d 896 (Conn. 1982). · cites it 4× “Since General Statutes § 51-243 (c) [1] expressly provides that alternate jurors shall not be segregated from the regular panel until the *79 case is submitted for deliberations, the possibility that the alternates were present during the luncheon conversation which gave rise to…”

Batick v. Seymour, 443 A.2d 471 (Conn. 1982). · cites it 2× “6 General Statutes § 51-241 provides as follows: “On the trial of any civil action to a jury, each party may challenge peremptorily three jurors.”

Marshall v. Hartford Hosp., 783 A.2d 1085 (Conn. App. Ct. 2001). · cites it 4× “Our case law, therefore, remains liberal in its interpretation of General Statutes § 51-241 and General Statutes § 51-243 as to the granting of peremptory challenges.”

Beach v. Reg'l Sch. Dist. No. 13, 682 A.2d 118 (Conn. App. Ct. 1996). · cites it 3× “The plaintiffs four peremptory challenges consisted of the three allowed by § 51-241 and the one allowed by General Statutes § 51-243 (a), which provides for additional peremptory challenges where alternate jurors are to be chosen.”

Hammer v. Mount Sinai Hosp., 596 A.2d 1318 (Conn. App. Ct. 1991). · cites it 2× ““Section 51-243 (a) of the General Statutes authorizes the trial court in a civil case to add two jurors to the jury panel to serve as alternate jurors.”

Rokus v. City of Bridgeport, 463 A.2d 252 (Conn. 1983). · cites it 2× “Section 51-243 (a) of the General Statutes authorizes the trial court in a civil case to add two jurors to the jury panel to serve as alternate jurors.”

Komondy v. Zoning Bd. of Appeals, 16 A.3d 741 (Conn. App. Ct. 2011). · cites it 2× “9 For good reason, the General Assembly has seen fit to require alternate jurors in civil and criminal cases alike to “be segregated from the regular panel .”

State v. Washington, 438 A.2d 1144 (Conn. 1980). “See § 51-243 (c) of the General Statutes (requiring that alternates be dismissed from further service on the case when the case is given to the regular jury panel for deliberation).”

Perry v. Hosp. of St. Raphael, 550 A.2d 645 (Conn. App. Ct. 1988). · cites it 10× “The defendant appeals, claiming that the trial court erred (1) in granting the plaintiff’s motion to preclude the defendant’s expert witness from offering testimony, (2) in admitting into evidence a statement contained in the records from a subsequent hospitalization of the…”

Show all 15 citing cases →

— Conn. Gen. Stat. § 51-243(a) — 1 case

Carrano v. Yale-New Haven Hosp., 904 A.2d 149 (Conn. 2006). “to 2001) § 51-243, [1] the plaintiff [2] was entitled to eight peremptory challenges and the defendants [3] were entitled to twenty because the trial court found that no unity of interest existed among them.”

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