Conn. Gen. Stat. » Title 52 — CIVIL ACTIONS · Chapter 925 — Statutory Rights of Action and Defenses
Connecticut General Statutes

Conn. Gen. Stat. § 52-572e (2026)

Release of joint tortfeasor

✓ current as of May 2026
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(a) For the purposes of this section the term “joint tortfeasors” means two or more persons jointly or severally liable in tort for the same injury to person or property whether or not a judgment has been recovered against all or any of them.

(b) A release by the injured person, or his legal representative, of one joint tortfeasor does not discharge the other tortfeasors unless, and only to the extent, the release so provides.

(1969, P.A. 143.)

Cited. 225 C. 401; 232 C. 272, 278; 234 C. 660. Enactment of statute was not intended to abrogate common law rule that a principal and agent are not joint tortfeasors, and therefore release of the primarily liable employee operated as a matter of law to release employer whose liability rested solely upon the doctrine of respondeat superior. 249 C. 709. Lessor and lessee of a motor vehicle are not joint tortfeasors within meaning of section and a release executed in favor of lessee also operates to release lessor. 260 C. 15.

Court may consider extrinsic evidence of the parties' intent regarding scope of the release. 72 CA 402.

Cited. 41 CS 353.

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Notes of Decisions
Cited in 22 cases (1 in the last 5 years), 1972–2022 · leading case: Alvarez v. New Haven Register, Inc., 735 A.2d 306 (Conn. 1999).
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Alvarez v. New Haven Register, Inc., 735 A.2d 306 (Conn. 1999). · cites it 50× “We first examine the language of § 52-572e to determine whether it clearly reflects the legislature’s intent to include situations involving vicarious liability. “A release by the injured person, or his legal representative, of one joint tortfeasor does not discharge the other…”
Embalmers' Supply Co. v. Giannitti, 929 A.2d 729 (Conn. App. Ct. 2007). · cites it 27× “A review of Sims and subsequent decisions reveals that the rule set forth in that case applies only in situations in which the normal rules of contract interpretation would operate to defeat the purpose of a remedial statute such as General Statutes § 52-572e. In Sims , the…”
Sims v. Honda Motor Co., 623 A.2d 995 (Conn. 1993). · cites it 30× “The sole issue in this case, on certification from the United States District Court, is whether, pursuant to General Statutes § 52-572e, 1 an alleged tortfeasor is, as a matter of law, discharged from liability to an injured party by virtue of a general release agreement…”
Cunha v. Colon, 792 A.2d 832 (Conn. 2002). · cites it 25× “The sole issue raised by this appeal is whether, notwithstanding General Statutes § 52-572e, 1 *17 a release executed in favor of the lessee of a motor vehicle operates as a matter of law to release the vehicle’s lessor whose claimed liability rests solely on General Statutes §…”
Viera v. Cohen, 927 A.2d 843 (Conn. 2007). · cites it 12× “, General Statutes § 52-572e. [We] hope that the legislature will be able to find a place on its busy agenda for inquiry into the consequences and the desirability of today's decision.”
Ramsay v. Camrac, Inc., 899 A.2d 727 (Conn. App. Ct. 2006). · cites it 15× “In Cunha , our Supreme Court held that a lessor and lessee are not joint tortfeasors under General Statutes § 52-572e (b) 5 and that a release executed in favor of a lessee also relieves a lessor of liability when sued pursuant to § 14-154a.”
Donner v. Kearse, 662 A.2d 1269 (Conn. 1995). · cites it 4× “General Statutes § 52-572e (b) provides in part that “[a] release by the injured person .”
Konover v. Kolakowski, 200 A.3d 1177 (Conn. App. Ct. 2018). · cites it 4× “In Sims , our Supreme Court recognized that its holding, which enabled the court to look beyond the four corners of a contract, even if the language was clear and unambiguous, was limited to the application of General Statutes § 52-572e, which relates to general releases.”
Caverly v. State, 342 Conn. 226 (Conn. 2022). · cites it 6× “The state recognizes that this common-law rule was abrogated by General Statutes § 52-572e, which provides in relevant part that a release of one joint tortfeasor ‘‘does not discharge the other tortfeasors unless, and only to the extent, the release so provides’’; General…”
Levine v. Massey, 654 A.2d 737 (Conn. 1995). · cites it 2× “Rigid application of that general rule would, however, frustrate the purposes of [General Statutes] § 52-572e, which counsels against uncritical enforcement of boilerplate general release language and, therefore, justifies treating such language differently from how we treat…”
Robbins v. Physicians for Women's Health, LLC, 38 A.3d 142 (Conn. App. Ct. 2012). · cites it 6× “[12] Although our legislature has abrogated the common-law result when releases are used in the joint tortfeasor context; see General Statutes § 52-572e (b) ("[a] release by the injured person .”
Squeglia v. Squeglia, 661 A.2d 1007 (Conn. 1995). · cites it 2× “General Statutes § 52-572e provides: “parent-child immunity abrogated in certain negligence actions.”
Show all 22 citing cases →
— Conn. Gen. Stat. § 52-572e(b) — 1 case
Moore v. Missouri Pac. R.R., 773 S.W.2d 78 (Ark. 1989).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.