Conn. Gen. Stat. » Title 52 — CIVIL ACTIONS · Chapter 903a — Prejudgment Remedies
Connecticut General Statutes

Conn. Gen. Stat. § 52-278b (2026)

Availability of prejudgment remedy

✓ current as of May 2026
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Notwithstanding any provision of the general statutes to the contrary, no prejudgment remedy shall be available to a person in any action at law or equity (1) unless he has complied with the provisions of sections 52-278a to 52-278g, inclusive, except an action upon a commercial transaction wherein the defendant has executed a waiver as provided in section 52-278f, or (2) for the garnishment of earnings as defined in subdivision (5) of section 52-350a.

(P.A. 73-431, S. 2, 8; P.A. 90-149, S. 2.)

History: P.A. 90-149 added Subdiv. (2) prohibiting the garnishment of earnings as a prejudgment remedy.

Cited. 176 C. 432; 181 C. 524; 184 C. 85; 188 C. 69; 208 C. 13; 222 C. 361; Id., 541; 232 C. 216.

Cited. 1 CA 188; 4 CA 510; 14 CA 579; 28 CA 809; 32 CA 118; 33 CA 223; 34 CA 801; 46 CA 399.

Cited. 38 CS 98. Subdiv. (2): Since commissions a real estate salesperson receive are debts accruing by reason of personal service, they are “earnings” under Sec. 52-350a(5) and are exempt from garnishment in a prejudgment remedy application. 50 CS 460.

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Notes of Decisions
Cited in 21 cases (2 in the last 5 years), 1980–2023 · leading case: Self-Serv. Sales Corp. v. Heinz, 470 A.2d 701 (Conn. App. Ct. 1983).
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Self-Serv. Sales Corp. v. Heinz, 470 A.2d 701 (Conn. App. Ct. 1983). · cites it 6× “First, he claims that General Statutes § 52-278b, when read with General Statutes § 52-278e (2), requires that, if the affidavit is inadequate, the prejudgment remedy must be dissolved.”
Blakeslee Arpaia Chapman, Inc. v. El Constructors, Inc., 628 A.2d 601 (Conn. App. Ct. 1993). · cites it 6× “” The plaintiff argues that pursuant to General Statutes § 52-278b, a prejudgment remedy is generally available in any action at law or in equity, and that the specific prejudgment remedy of attachment is generally available in any action where the applicant seeks money damages.”
Ford Motor Credit Co. v. B. W. Beardsley, Inc., 542 A.2d 1159 (Conn. 1988). · cites it 3× “The defendant argues that the “inclusive” language of General Statutes § 52-278b 4 providing that “no *19 prejudgment remedy shall be available to a person in any action at law or equity unless he has complied with the provisions of sections 52-278a to 52-278g, inclusive”…”
Bahrain Telecomm. Co. v. Discoverytel, Inc., 476 F. Supp. 2d 176 (D. Conn. 2007). · cites it 3× “Batelco has not sought to obtain a prejudgment remedy directly under Conn. Gen.Stat. § 52-278b, Connecticut's general prejudgment remedy section.”
Bd. of Educ. v. Booth, 654 A.2d 717 (Conn. 1995). · cites it 11× “The sole question raised by this appeal is whether the plaintiff, the board of education of the town of East Hartford, is precluded by General Statutes § 52-278b 1 from obtaining a prejudgment garnishment of certain moneys it owes to the defendant, Gary A.”
Town of East Lyme v. Wood, 735 A.2d 843 (Conn. App. Ct. 1999). · cites it 5× “The defendants claim that the trial court improperly found that (1) a prior injunction authorized the plaintiff to enter upon the defendants’ land, (2) it had subject matter jurisdiction over a motion for payment and (3) the plaintiff complied with General Statutes § 52-278b. We…”
England v. England, 440 A.2d 790 (Conn. 1981). · cites it 4× “) That prejudgment remedies are available in both legal and equitable proceedings is clearly demonstrated by General Statutes § 52-278b, which refers to the availability of such remedies “in any action at law or equity.”
People's Bank v. Bilmor Bldg. Corp., 614 A.2d 456 (Conn. App. Ct. 1992). · cites it 2× “General Statutes § 52-278b provides for prejudgment remedies in “any action at law or equity.”
Lauf v. James, 635 A.2d 300 (Conn. App. Ct. 1993). · cites it 3× “General Statutes § 52-278b provides that “no prejudgment remedy shall be available to a person in any action at law or equity .”
Essex Grp., Inc. v. Ducci Elec. Co., 436 A.2d 16 (Conn. 1980). · cites it 2× “General Statutes § 52-278b; Ledgebrook Condominium Assn.”
In Re Morzella, 171 B.R. 485 (Bankr. D. Conn. 1994). · cites it 2× “The most reasonable interpretation of this section is that the Act applies to any prejudgment attachment, see Conn.Gen. Stat. § 52-278b, or judgment lien, see id.”
Davila v. Secure Pharmacy Plus, 329 F. Supp. 2d 311 (D. Conn. 2004). · cites it 2× “Connecticut General Statutes § 52-278b provides that “no prejudgment remedy shall be available to a person in any action at law or in equity (1) unless he has complied with the provisions of sections 52-278a to 52-278g inclusive .”
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