Conn. Gen. Stat. » Title 52 — CIVIL ACTIONS · Chapter 900 — Court Practice and Procedure
Connecticut General Statutes

Conn. Gen. Stat. § 52-226a (2026)

Special finding that action or defense without merit and not in good faith

✓ current as of May 2026
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In any civil action tried to a jury, after the return of a verdict and before judgment has been rendered thereon, or in any civil action tried to the court, not more than fourteen days after judgment has been rendered, the prevailing party may file a written motion requesting the court to make a special finding to be incorporated in the judgment or made a part of the record, as the case may be, that the action or a defense to the action was without merit and not brought or asserted in good faith. Any such finding by the court shall be admissible in any subsequent action brought pursuant to section 52-568.

(P.A. 86-338, S. 8; P.A. 87-526, S. 2, 5; P.A. 00-196, S. 60.)

History: P.A. 87-526 added “subsection (a) of”; P.A. 00-196 deleted reference to “subsection (a) of” Sec. 52-568.

Cited. 214 C. 1.

Cited. 44 CA 641.

Cited. 41 CS 169.

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Notes of Decisions
Cited in 10 cases, 1988–2020 · leading case: Pellet v. Keller Williams Realty Corp., 172 A.3d 283 (Conn. App. Ct. 2017).
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Pellet v. Keller Williams Realty Corp., 172 A.3d 283 (Conn. App. Ct. 2017). · cites it 18× “from the judgment of the trial court directing a verdict in favor of the defendants Keller Williams Realty Corporation (Keller Williams), Michael Ladden, David Olson, Pina Jenkins, Jason Kilduff, and Kimberly Kilduff 2 as to all eight counts of the plaintiff's substitute…”
Stamford Hosp. v. Schwartz, 209 A.3d 1243 (Conn. App. Ct. 2019). · cites it 5× “" General Statutes § 52-226a provides in relevant part: "In any civil action .”
Tzovolos v. Wiseman, 12 A.3d 563 (Conn. 2011). · cites it 5× “The trial court subsequently granted in part the motion of the plaintiffs in the first action for a special finding pursuant to General Statutes § 52-226a, 9 that Jason Robert’s Concrete, Hartmann, Sr.”
Tatoian v. Tyler, 194 Conn. App. 1 (Conn. App. Ct. 2019). · cites it 4× “Fifth, the defendants claimed that in the present action the plaintiff had vio- lated General Statutes § 52-226a by failing to obtain a certificate from the court in the prior action confirming that the action was vexatious in nature.”
Beverly v. State, 691 A.2d 1093 (Conn. App. Ct. 1997). · cites it 3× “Section 52-226a provides in pertinent part: “In any civil action tried to a jury, after the return of a verdict and before judgment has been rendered thereon .”
Tautic v. Pattillo, 561 A.2d 988 (Conn. Super. Ct. 1988). · cites it 2× “2d 164 (1985); see also General Statutes § 52-226a (requiring the court to make a posttrial special finding upon motion that the action is without merit and was not brought in good faith).”
Loricco v. Pantani, 789 A.2d 514 (Conn. App. Ct. 2002). · cites it 4× “After the court rendered judgment on February 1, 2000, the plaintiff filed a motion for a special finding against Maire pursuant to General Statutes § 52-226a, 7 claiming that her actions and defenses in the case were without merit and brought in bad faith.”
Miller v. Appellate Court (Conn. 2016). · cites it 3× “6 General Statutes § 52-226a provides: ‘‘In any civil action tried to a jury, after the return of a verdict and before judgment has been rendered thereon, or in any civil action tried to the court, not more than fourteen days after judgment has been rendered, the prevailing…”
Off. of Chief Disciplinary Couns. v. Miller (Conn. 2020). · cites it 2× “The trial court subsequently entered a summary judgment against the plaintiff, and the court supplemented its decision with a special find- ing pursuant to General Statutes § 52-226a that the refiled action was meritless and not brought in good faith.”
Off. of Chief Disciplinary Couns. v. Miller (Conn. 2020). · cites it 2× “The trial court subsequently entered a summary judgment against the plaintiff, and the court supplemented its decision with a special find- ing pursuant to General Statutes § 52-226a that the refiled action was meritless and not brought in good faith.”
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