Connecticut General Statutes

Conn. Gen. Stat. § 52-420 (2026)

Motion to confirm, vacate or modify award

✓ current as of May 2026

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(a) Any application under section 52-417, 52-418 or 52-419 shall be heard in the manner provided by law for hearing written motions at a short calendar session, or otherwise as the court or judge may direct, in order to dispose of the case with the least possible delay.

(b) No motion to vacate, modify or correct an award may be made after thirty days from the notice of the award to the party to the arbitration who makes the motion.

(c) For the purpose of a motion to vacate, modify or correct an award, such an order staying any proceedings of the adverse party to enforce the award shall be made as may be deemed necessary. Upon the granting of an order confirming, modifying or correcting an award, a judgment or decree shall be entered in conformity therewith by the court or judge granting the order.

(1949 Rev., S. 8163; P.A. 82-160, S. 159.)

History: P.A. 82-160 rephrased the section and inserted Subsec. indicators.

Cited. 136 C. 206. Filing motion with clerk of Superior Court within time limited is sufficient though notice not given defendants until after that time. 137 C. 298. Cited. 146 C. 17. Procedure re modification of award discussed. 147 C. 139. Cited. 149 C. 691; 155 C. 278; 163 C. 327; 176 C. 401; 179 C. 678; 181 C. 449; 190 C. 323; 197 C. 26; 200 C. 376; 201 C. 50; 206 C. 113; 208 C. 352; 212 C. 83; 217 C. 110; 225 C. 339; 226 C. 475; 229 C. 359. Section does not require a movant to articulate the factual basis for a motion to vacate, modify or correct an arbitration award. 337 C. 127.

Cited. 4 CA 339; 7 CA 272; 20 CA 1, 5; 29 CA 736; 32 CA 250; 33 CA 1; 36 CA 29; 39 CA 122; Id., 444. In matter where trial court had confirmed arbitration award, and thereafter no motion to modify the judgment was filed within requisite 30-day period, trial court committed reversible error when it added requirement that plaintiff's assignment of interest in certain property to defendant was a prerequisite to granting of a bank execution in plaintiff's favor; trial court's action amounted to improper modification of arbitration award rather than effectuation of the award. 88 CA 74. Dismissal of the arbitration is not a final resolution of the underlying claim on the merits and does not conclusively resolve the rights and obligations of the parties and thus, court lacked subject matter jurisdiction over the plaintiff's application to vacate. 210 CA 788.

Fact that notice of the application was given defendants by a summons rather than by a rule to show cause is not important. 16 CS 505. Contemplates and permits procedure involving use of motions in substitution for conventional forms of pleading. 20 CS 91. Taxation of costs for such proceedings are in the discretion of the court as there is no provision otherwise in the statutes. 21 CS 331. Cited. 29 CS 25; Id., 289; 45 CS 130.

Failure to move under statute will preclude aggrieved party from seeking correction of award in circuit court. 2 Conn. Cir. Ct. 66.

Subsec. (a):

When the parties' dispute concerns one arbitration award, reviewing an application to vacate and an application to confirm simultaneously, in furtherance of judicial economy, is a reasonable way to “dispose of the case with the least possible delay”; language of Subsec. plain and unambiguous. 161 CA 348.

Subsec. (b):

Claim of fraud does not toll the 30-day period within which a motion to vacate arbitration award must be filed pursuant to Subsec. 264 C. 307. The 30-day filing period applies to an application to vacate an arbitration award on the ground that it violates public policy. 285 C. 278. Subsec. implicates a trial court's subject matter jurisdiction and that the choice of law provision contained in parties' private agreement could neither enlarge the trial court's jurisdiction over the plaintiff's application nor waive the jurisdictional defect; Subsec. does not stand as an obstacle to the accomplishment of the federal policy to enforce arbitration agreements under the Federal Arbitration Act. 338 C. 651.

Trial court's action in setting appropriate amount of compensation essentially operated as a modification of the judgment confirming arbitration award and was improper since it came after expiration of the 30-day period. 72 CA 334. It is not necessary to file motion to vacate an award within the time frame set forth in statute in cases where the arbitration award has no legal effect due to the arbitrator's untimely award, and the parties' lack of waiver of 30-day requirement. 100 CA 373. The 30-day filing period in Subsec. applies to a motion to vacate an arbitration award on the ground that it violates public policy. 108 CA 360. Compliance with section requires timely filing of an application to vacate an arbitration award, not timely service. 165 CA 467. Parties cannot contract around, by way of choice of law provision, the subject matter jurisdictional nature of Subsec., applicable to any application to vacate arbitration award brought in Connecticut state court. 192 CA 245; judgment affirmed, see 338 C. 651. Time limitation of Subsec. does not apply in situations where arbitration award in dissolution proceeding has been obtained by fraud and made part of dissolution judgment pursuant to Sec. 46b-66(e). 228 CA 163.

Request to the arbiter for modification of an award to correct a typographical error does not toll the period within which to file an application to vacate the award. 52 CS 592; judgment affirmed, see 144 CA 77.

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Notes of Decisions

Cited in 79 cases (7 in the last 5 years), 1959–2025 · leading case: A Better Way Wholesale Autos, Inc. v. Saint Paul.

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A Better Way Wholesale Autos, Inc. v. Saint Paul (Conn. 2021). · cites it 63× “First, we con- sider whether the Connecticut thirty day time limitation applicable to a motion to vacate an arbitration award, General Statutes § 52-420 (b),1 implicates the subject matter jurisdiction of our courts.”

Town of Bloomfield v. United Elec., Radio & Mach. Workers of Am. (Conn. 2008). · cites it 35× “The dispositive issue in this appeal is whether the thirty day limitations period of General Statutes § 52-420 (b) 1 applies to an application to vacate an arbitration award based solely on the common-law ground that the award violates public policy.”

Blondeau v. Baltierra (Conn. 2020). · cites it 19× “II TRIAL COURT’S JURISDICTION A Timeliness Under General Statutes § 52-420 The defendant advances a number of jurisdictional claims of his own.”

Ko Shu Mei Wu v. Chung-Ming Chang (Conn. 2003). · cites it 17× “The sole issue raised by this appeal is whether a claim of fraud tolls the thirty day period within which a motion to vacate an arbitration award must be filed pursuant to General Statutes § 52-420 (b). 1 We conclude that the trial court properly determined that a claim of fraud…”

Brunswick v. Statewide Grievance Comm. (Conn. App. Ct. 2007). · cites it 10× “Although the amount and the time billed was related to requesting the arbitrator to sit on the case, it was argued that the one and one-half hours billed far exceeded the reasonable time such request would require, thereby suggesting an inference that the merits of the case may…”

Middlesex Ins. v. Castellano (Conn. 1993). · cites it 13× “In its memorandum of decision, the trial court stated that the plaintiff had filed its motion to vacate within the thirty day time limit set forth by General Statutes § 52-420 (b), 2 and that notice had been given within a reasonable period of time.”

Remax Right Choice v. Aryeh (Conn. App. Ct. 2007). · cites it 10× “Specifically, the court stated: “After hearing and consideration of the evidence, [the] court finds that the defendant did not make a timely motion to vacate per General Statutes § 52-420 (b) and that the parties waived [any objection to] the late filing of the award by failing…”

Karen v. Loftus (Conn. App. Ct. 2024). · cites it 24× “We are not per- suaded by the defendant’s jurisdictional claim and agree with the plaintiff that the court improperly concluded that she had failed to establish probable cause as to her fraud claim.3 Accordingly, we reverse the judgment denying the plaintiff’s motion to open and…”

MBNA Am. Bank, N.A. v. Boata (Conn. 2007). · cites it 7× “See General Statutes § 52-420 (b). 4 The trial court rendered judgment confirming the award, and the defendant appealed to the Appellate Court from the trial court’s judgment, claiming that the trial court improperly had concluded that he had failed to assert his right to…”

Girolametti v. Michael Horton Assocs., Inc. (Conn. 2019). · cites it 4× “Rather, their primary claim is that, in early November, 2010, prior to the conclusion of the arbitration, Rizzo and certain of the defendants became aware of alleged defects in the project design but conspired to fraudulently conceal those defects from the *1233 plaintiffs so…”

Rosenthal Law Firm, LLC v. Cohen (Conn. App. Ct. 2016). · cites it 8× “General Statutes § 52-420(b) creates a time limitation on bringing a motion to vacate: No motion to vacate, modify or correct an award may be made after thirty days from the notice of the award to the party to the arbitration who makes the motion.”

Spearhead Constr. Corp. v. Bianco (Conn. App. Ct. 1995). · cites it 9× “See General Statutes § 52-420 (“[a]ny application .”

Show all 79 citing cases →

— Conn. Gen. Stat. § 52-420(b) — 9 cases

Rosenthal Law Firm, LLC v. Cohen (Conn. App. Ct. 2016). “General Statutes § 52-420(b) creates a time limitation on bringing a motion to vacate: No motion to vacate, modify or correct an award may be made after thirty days from the notice of the award to the party to the arbitration who makes the motion.”

Brunswick v. Statewide Grievance Comm. (Conn. App. Ct. 2007). “Although the amount and the time billed was related to requesting the arbitrator to sit on the case, it was argued that the one and one-half hours billed far exceeded the reasonable time such request would require, thereby suggesting an inference that the merits of the case may…”

Coldwell Banker Manning Realty, Inc. v. Cushman & Wakefield (Conn. 2009).

Doctor's Assocs., Inc. v. Searl (Conn. App. Ct. 2018).

Middlesex Mut. Assurance Co. v. Komondy (Conn. App. Ct. 2010).

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