Connecticut General Statutes

Conn. Gen. Stat. § 52-405 (2025)

Appeal in action demanding an accounting

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When, in any action demanding an accounting, a judgment is rendered ordering such accounting, appeal may be had from such judgment to the Appellate Court, as if it were a final judgment. Such appeal shall have precedence in the Appellate Court.

(1949 Rev., S. 8004; June Sp. Sess. P.A. 83-29, S. 45, 82.)

History: June Sp. Sess. P.A. 83-29 deleted reference to supreme court and substituted appellate court in lieu thereof.

Cited. 68 C. 61; 82 C. 425. If judge makes finding on judgment for accounting, need not make one as to same facts after account is taken. 87 C. 400. Appeal lies from interlocutory judgment refusing to order an accounting. 102 C. 122. Cited. 185 C. 320; 222 C. 331.

Cited. 5 CA 457.

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Notes of Decisions

Cited in 6 cases (2 in the last 5 years), 1985–2023 · leading case: State v. Ayala, 610 A.2d 1162 (Conn. 1992).

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State v. Ayala, 610 A.2d 1162 (Conn. 1992). · cites it 2× “, General Statutes § 54-56e (denial of motion to dismiss upon completion of accelerated rehabilitation program or termination of participation in such a program). There is, however, no statutory authority that confers on the defendant a right to an interlocutory appeal in this…”

Zuch v. Connecticut Bank & Trust Co., 500 A.2d 565 (Conn. App. Ct. 1985). · cites it 2× “General Statutes § 52-405 provides in pertinent part: “When, in any action demanding an accounting, a judgment is rendered ordering such accounting, appeal may be had from such judgment to the appellate court, as if it were a final judgment.”

Gelinas v. Gelinas (In Re Gelinas), 270 B.R. 88 (Bankr. D. Conn. 2001). · cites it 4× “The court declines to accept the debtor’s argument that under Connecticut procedure Judge Hennessey’s judgment ordering an accounting is not sufficiently final for the application of the Rooker-Feldman doctrine.”

Cunniffe v. Cunniffe, 91 A.3d 497 (Conn. App. Ct. 2014). · cites it 2× “…bail); General Statutes § 54-47g (a) (grand jury disclo- sures); General Statutes § 51-164x (court closure orders); General Statutes § 52-405 (accounting); General Statutes § 54-56e (f) (denial of motion to dismiss after completion of accelerated rehabilitation program). 11…”

Smith v. Supple, 293 A.3d 851 (Conn. 2023). · cites it 2× “remedy ‘‘shall be deemed a final judgment for purposes of appeal’’); General Statutes § 52-405 (‘‘[w]hen, in any action demanding an accounting, a judgment is rendered ordering such accounting, appeal may be had from such judgment to the Appellate Court, as if it were a final…”

Smith v. Supple, 293 A.3d 851 (Conn. 2023). · cites it 2× “judgment remedy ‘‘shall be deemed a final judgment for purposes of appeal’’); General Statutes § 52-405 (‘‘[w]hen, in any action demanding an accounting, a judgment is rendered ordering such accounting, appeal may be had from such judgment to the Appellate Court, as if it were a…”

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