Connecticut General Statutes

Conn. Gen. Stat. § 52-564 (2026)

Treble damages for theft

✓ current as of May 2026

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Any person who steals any property of another, or knowingly receives and conceals stolen property, shall pay the owner treble his damages.

(1949 Rev., S. 8305; 1963, P.A. 99.)

History: 1963 act provided recovery be treble damages rather than treble the value of the property stolen.

See chapter 952, part IX, re larceny, robbery and related offenses.

In a public prosecution for theft, the court will not on conviction award treble damages to the owner. 6 C. 105. Plaintiff not bound to prove his case “beyond a reasonable doubt”. 30 C. 103. Rules of evidence are the same as in any civil suit. Id., 556. Not a penal statute. 74 C. 135; 87 C. 468. Is constitutional. 82 C. 5. Statutory treble damages discussed. 188 C. 36. Cited. 206 C. 125; 216 C. 200; 236 C. 582; 241 C. 678. Statutory theft under section is synonymous with larceny as provided in Sec. 53a-119; statutory theft requires that defendant wrongfully take, obtain or hold property of another. 255 C. 20. Preponderance of the evidence standard of proof applies to statutory theft claims brought under section. 297 C. 26. The litigation privilege applies to bar plaintiff's statutory theft claim. 341 C. 1.

Cited. 1 CA 303; 8 CA 96; 11 CA 161; 18 CA 20; 33 CA 303; 37 CA 7; 42 CA 599; 43 CA 1; 45 CA 46; Id., 324. Statute synonymous with larceny under Sec. 53a-119. 47 CA 517. Liability for conversion is a precondition to finding of liability for treble damages under section. 86 CA 527. Because count of plaintiff's complaint alleging civil theft is devoid of any factual assertion that defendants acted with the requisite intent to permanently deprive plaintiff of her property, plaintiff failed to state a cause of action for civil theft, and count is legally insufficient. 99 CA 719. Plaintiff is required to prove the actions alleged by clear and convincing evidence in order to be entitled to an award of treble damages. 112 CA 160; judgment reversed in part, see 297 C. 26. In order to prove liability under section, plaintiff only had to show that defendant engaged in conduct that was synonymous with larceny, and was not required to show that the funds had been stolen by defendant or anyone else; given defendant's knowledge concerning source and disposition of funds in question, his continued failure to return funds constituted an intentional decision on his part to deprive plaintiff of its use of funds. 136 CA 99. The essential elements plaintiffs must prove to obtain treble damages for civil theft are the same as the elements to prove larceny: (1) An intent to do the act complained of, (2) the act was done wrongfully, and (3) the act was committed against an owner. 138 CA 695. Benefit on behalf of defendant is not an element of statutory theft; an intent to deprive plaintiff of funds could be inferred from fact that defendant withdrew funds that were not used for the benefit of the beneficiary and the trust had been exhausted. 139 CA 794. Injunctive relief is not a remedy available under section and since plaintiffs have made no tuition payments there is no loss of property; no theft can occur absent the loss of property. 191 CA 360. A claim for civil theft of funds must be for specific identifiable money and cannot arise from an implied contract of unjust enrichment. 196 CA 583. There is no basis for precluding the application of absolute immunity to a statutory theft claim that does not challenge the underlying purpose of the litigation but, instead, challenges the alleged misconduct of the defendant in his role as an attorney on behalf of his client; Public policy does not support permitting claims of statutory theft against attorneys, as it would inhibit participation and candor in judicial proceedings, and have a chilling effect on the attorney-client relationship and on an attorney's zealous representation of his or her client. 198 CA 197; judgment affirmed, see 341 C. 1.

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Notes of Decisions

Cited in 187 cases (46 in the last 5 years), 1982–2026 · leading case: Stuart v. Stuart, 996 A.2d 259 (Conn. 2010).

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Stuart v. Stuart, 996 A.2d 259 (Conn. 2010). · cites it 43× “In this certified appeal, 1 we are called on to determine what standard of proof applies to statutory theft claims brought pursuant to General Statutes § 52-564. 2 The plaintiffs, William A.”

Lauder v. Peck, 526 A.2d 539 (Conn. App. Ct. 1987). · cites it 34× “1 The trial court further found that the defendant committed two larcenies of the plaintiffs money in violation of General Statutes § 53a-119, and that the defendant was therefore liable to the plaintiff for treble damages pursuant to General Statutes § 52-564. 2 The forgery and…”

Stuart v. Stuart, 962 A.2d 842 (Conn. App. Ct. 2009). · cites it 19× “, constituted statutory theft pursuant to General Statutes § 52-564 and that Stuart, Jr.”

Mystic Color Lab, Inc. v. Auctions Worldwide, LLC, 934 A.2d 227 (Conn. 2007). · cites it 14× “3 The defendants claim that the trial court improperly (1) concluded that the defendants were liable in tort for the conversion of proceeds from an auction of Mystic’s photo processing equipment, (2) concluded that the defendants were liable for statutory theft of the auction…”

A-G Foods, Inc. v. Pepperidge Farm, Inc., 579 A.2d 69 (Conn. 1990). · cites it 8× “The plaintiff maintains that General Statutes § 52-564 imposes liability for treble damages upon a principal who is vicariously liable for the acts of its agent.”

Suarez-Negrete v. Trotta, 705 A.2d 215 (Conn. App. Ct. 1998). · cites it 13× “The court found, by clear and convincing evidence, that the defendant had converted the plaintiffs money and, therefore, awarded treble damages pursuant to General Statutes § 52-564. 1 The court awarded prejudgment interest, pursuant to General Statutes § 37-3a, 2 from April…”

Schaffer v. Lindy, 511 A.2d 1022 (Conn. App. Ct. 1986). · cites it 13× “The defendant’s third claim of error is that the trial court utilized the incorrect standard of proof to support an award of treble damages pursuant to General Statutes § 52-564. 1 In his first claim of error, the defendant directly attacks the admission of the alleged hearsay…”

Certain Underwriters at Lloyd's, London v. Cooperman, 957 A.2d 836 (Conn. 2008). · cites it 7× “The complaints further alleged that the defendants intentionally had deprived the plaintiffs of funds and other assets, which the defendants diverted to their own use and accounts, thus constituting statutory theft in violation of General Statutes § 52-564 10 (count three), and…”

Alaimo v. Royer, 448 A.2d 207 (Conn. 1982). · cites it 6× “ensation for her financial loss; compensation for her emotional distress and mental anguish; punitive damages, which include “such things as Miss Alaimo’s *42 attorney’s fees, and the costs and expenses of bringing the action”; and exemplary damages, which are “defined by…”

Scholz v. Epstein, 341 Conn. 1 (Conn. 2021). · cites it 8× “See General Statutes § 52-564; see also part II B of this opinion.”

Deming v. Nationwide Mut. Ins., 905 A.2d 623 (Conn. 2006). · cites it 5× “Three counts related to the defendants’ control over and access to the plaintiffs’ “book of business, 7 including the renewals in violation of [§] 38a-709 (c)”: misappropriation (conversion); theft in violation of General Statutes § 52-564; 8 and breach of contract, including…”

Howard v. MacDonald, 851 A.2d 1142 (Conn. 2004). · cites it 10× “General Statutes § 52-564 provides: “Any person who steals any property of another, or knowingly receives and conceals stolen property, shall pay the owner treble his damages.”

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