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

Conn. Gen. Stat. § 52-596 (2026)

Actions for payment of remuneration for employment

✓ current as of May 2026
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No action for the payment of remuneration for employment payable periodically shall be brought but within two years after the right of action accrues, except that this limitation shall be tolled upon the filing with the Labor Commissioner of a complaint of failure to pay wages pursuant to the provisions of chapter 558.

(1949 Rev., S. 8336; P.A. 80-182.)

History: P.A. 80-182 added exception re filing of complaint for failure to pay wages with labor commissioner.

Does not apply to severance pay which is not within description of “payment of remuneration for employment payable periodically”. 155 C. 680. Cited. 214 C. 464.

Cited. 11 CA 375; 16 CA 232; 43 CA 435. Payments must occur at regular intervals to qualify as periodic payments. 96 CA 673.

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Notes of Decisions
Cited in 29 cases (13 in the last 5 years), 1967–2026 · leading case: Schoonmaker v. Lawrence Brunoli, Inc., 828 A.2d 64 (Conn. 2003).
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Schoonmaker v. Lawrence Brunoli, Inc., 828 A.2d 64 (Conn. 2003). · cites it 6× “11 The defendants interposed the following special defenses: (1) that some or all of the plaintiffs’ causes of action were barred by the applicable statute of limitations, General Statutes § 52-596; 12 (2) that the claims arising out of the UCONN project for three of the…”
Duplissie v. Devino, 902 A.2d 30 (Conn. App. Ct. 2006). · cites it 13× “B On his appeal, Devino claims that the court incorrectly concluded that the plaintiffs claims as to the *683 promise to pay an annual sum were not barred by the limitations periods in General Statutes §§ 52-596 and 52-576. “Whether a party’s claim is barred by the statute of…”
Quiello v. Reward Network Establishment Servs., Inc., 420 F. Supp. 2d 23 (D. Conn. 2006). · cites it 11× “8 RNI has moved for summary judgment on all of these claims, arguing, inter alia, that, under the terms of the 2004 Plan and prior Plans, Quiello cannot demonstrate that it has breached any contract with Quiello, and that Quiello’s loss deduction claim is barred by the statute…”
Evans v. Tiger Claw, Inc., 61 A.3d 533 (Conn. App. Ct. 2013). · cites it 8× “The defendants filed special defenses alleging that the plaintiffs claims were *114 barred by the statute of limitations; General Statutes § 52-596; and by the doctrine of res judicata.”
Lisa ASP & Paulette Mertes v. Milardo Photography, Inc., 573 F. Supp. 2d 677 (D. Conn. 2008). · cites it 4× “§ 255(a); Conn. Gen.Stat. § 52-596. Here, the cause of action commenced on June 22, 2004, so all claims prior to June 22, 2002, are barred unless they can be tolled.”
Shortt v. New Milford Police Dep't, 562 A.2d 7 (Conn. 1989). · cites it 2× “his entitlement to wages nor the amount thereof had been determined under the grievance procedure contained in the collective bargaining agreement? (2) Did the Appellate Court err in holding that § 31-72 of the Connecticut General Statutes was applicable to the defendant as an…”
Veeder-Root Co. v. Comm'n on Human Rights & Opportunities, 334 A.2d 443 (Conn. 1973). · cites it 4× “" Since this is the only time limitation contained in chapter 563, the trial court was correct in concluding that that limitation governed rather than the general two-year statutory limitation in General Statutes § 52-596, stating that "[t]he clear import of § 31-127 is to…”
Amara v. Cigna Corp., 534 F. Supp. 2d 288 (D. Conn. 2008). “§ 52-596, is more appropriate. Every decision of the Second Circuit that the Court has found holds that the most closely analogous state statute of limitations for employee benefit claims similar to Plaintiffs’ is that for written contracts.”
MacE v. Conde Nast Publications, Inc., 237 A.2d 360 (Conn. 1967). · cites it 2× “The defendant pleaded, in its sixth special defense, that the action was barred by G-eneral Statutes § 52-596, which provides that “ [n] o action for the payment of remuneration for employment payable periodically shall be brought but within two years after the right of action…”
Stiegler v. Meriden, 348 Conn. 452 (Conn. 2024). · cites it 2× “’’ With respect to the plaintiffs’ lost wages claims, however, the trial court determined that those claims were barred by the two year statute of limitations in General Statutes § 52-596. See General Statutes § 52- 596 (‘‘[n]o action for the payment of remuneration for…”
Brunoli v. Fred Brunoli & Sons, Inc. Pension Plan, 993 F. Supp. 66 (D. Conn. 1997). · cites it 2× “Conn. Gen. Stat. § 52-596 . With respect to ERISA claims that do not allege a breach of fiduciary duty, ERISA is silent as to the applicable limitations period.”
Richardson v. Costco Wholesale Corp., 169 F. Supp. 2d 56 (D. Conn. 2001). · cites it 2× “Accordingly, the court deems this portion of plaintiffs’ claims to be waived. This ruling addresses the arguments relevant to defendant’s lock-in closing procedures.”
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