Conn. Gen. Stat. » Title 52 — CIVIL ACTIONS · Chapter 926 — Statute of Limitations
Connecticut General Statutes

Conn. Gen. Stat. § 52-585 (2026)

Suit for forfeiture on penal statute limited to one year

✓ current as of May 2026
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No suit for any forfeiture upon any penal statute shall be brought but within one year next after the commission of the offense. The provisions of this section shall not apply to any civil action brought by the state or a municipality, or any officer or agent thereof, to recover a forfeiture or civil penalty.

(1949 Rev., S. 8325; P.A. 91-312, S. 44.)

History: P.A. 91-312 added provision re nonapplicability to any civil action brought by the state or a municipality to recover a forfeiture or civil penalty.

Amendment of declaration will not be allowed after the year. 4 D. 37. Cited. 56 C. 23; 57 C. 54, 55. A bylaw prohibiting any excavation in the highway held a penal statute. 64 C. 429. Statute giving additional compensation for cutting trees on another's land not penal. 74 C. 134. Where statute gives forfeiture for each month's delay, no recovery can be had except for year preceding action. 76 C. 559. Does not apply to action for liquidated damages for which employer is liable under federal Fair Labor Standards Act. 134 C. 257. Cited. 214 C. 464.

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Notes of Decisions
Cited in 7 cases (3 in the last 5 years), 1985–2026 · leading case: Brown v. Rawlings Fin. Servs., LLC, 868 F.3d 126 (2d Cir. 2017).
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Brown v. Rawlings Fin. Servs., LLC, 868 F.3d 126 (2d Cir. 2017). · cites it 2× “B The district court ruled that the Connecticut statute of limitations for “civil forfeiture” is the one most closely analogous to requests for statutory damages under Section 502(c)(1): No suit for any forfeiture upon any penal statute shall be brought but within one year next…”
Connecticut Fund for Env't v. Job Plating Co., 623 F. Supp. 207 (D. Conn. 1985). · cites it 2× “In this case, the defendant contends that the applicable statute of limitations is one year pursuant to Conn.Gen.Stat. § 52-585 (civil penalty actions), or three years under the statute governing nuisance actions.”
Connex Credit Union v. Madgic (Conn. 2026). · cites it 25× “Madgic General Statutes § 52-585 for “suit[s] for any forfeiture upon any penal statute” applies to claims for damages brought under article 9 of the Uniform Commercial Code (UCC), General Statutes § 42a-9-101 et seq.”
Mut. Sec. Credit Union v. Hardy (Conn. 2026). · cites it 7× “1 The trial court subsequently granted the plaintiff’s motion for summary judgment, concluding that the defendant’s counterclaim for damages under General Statutes §§ 42a-9-625 and 36a-785 was time barred by the one year statute of limitations set forth in General Statutes §…”
Lumpkin v. Nutmeg State Fin. Credit Union (Conn. 2026). · cites it 7× “The trial court granted the defendant’s motion for summary judgment, concluding that the plaintiff’s claims for damages under General Statutes §§ 42a-9-625 and 36a-785 were time barred by the one year statute of limitations set forth in General Statutes § 52-585 for “suit[s] for…”
Brown v. Rawlings Fin. Servs., LLC, 211 F. Supp. 3d 480 (D. Conn. 2016). · cites it 5× “Defendants claim that Section 502(c) is most closely analogous to a civil penalty and that this Court should apply Conn. Gen Stat § 52-585, which imposes a one year statute of limitations for actions for “forfeiture upon any penal statute,” to this claim.”
Gonzalez ex rel. Gonzalez v. Johnson, 23 Mass. L. Rptr. 262 (Mass. Super. Ct. 2007). · cites it 2× “Conn. Gen. Stat. §52-585 . For the following reasons, the defendants’ motion is ALLOWED.”
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