Conn. Gen. Stat. » Title 52 — CIVIL ACTIONS · Chapter 898 — Pleading
Connecticut General Statutes

Conn. Gen. Stat. § 52-99 (2026)

Untrue allegations or denials; costs

✓ current as of May 2026
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Any allegation or denial made without reasonable cause and found untrue shall subject the party pleading the same to the payment of such reasonable expenses, to be taxed by the court, as may have been necessarily incurred by the other party by reason of such untrue pleading; provided no expenses for counsel fees shall be taxed exceeding five hundred dollars for any one offense.

(1949 Rev., S. 7821; P.A. 22-26, S. 43.)

History: P.A. 22-26 replaced $10 with $500.

General denial improper where part of claim is admittedly true. 67 C. 76. Pleader must not take totally inconsistent positions. 82 C. 592, but see 82 C. 623. Effect of violation of this rule; failure of other party to claim penalty; judgment is not invalidated. 99 C. 167. Expenses should be deducted where prevailing party has violated rule. 107 C. 494. One who violates rule not precluded from setting up own defenses in pleading. 124 C. 536. Cited. 218 C. 65. Statute didn't abrogate common law immunity against insurer's knowingly false communications in judicial proceedings as safeguards other than civil liability exist to deter misconduct and provide relief. 342 C. 582.

Cited. 18 CA 344.

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Notes of Decisions
Cited in 8 cases (6 in the last 5 years), 1989–2025 · leading case: Fattibene v. Kealey, 558 A.2d 677 (Conn. App. Ct. 1989).
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Fattibene v. Kealey, 558 A.2d 677 (Conn. App. Ct. 1989). · cites it 6× “The legal bases of the *349 motion were Practice Book § 111, 1 General Statutes § 52-99, 2 General Statutes § 51-84, 3 “the court’s announced policy of enforcing rule 11 of the Federal Rules of Civil Procedure in this Judicial District,” and “the court’s inherent power to…”
Dorfman v. Liberty Mut. Fire Ins. Co., 227 Conn. App. 347 (Conn. App. Ct. 2024). · cites it 13× “) Because the defendant does not argue that a vexatious litigation action cannot be premised on a special defense filed in a prior action without probable cause, we limit our discussion to the question of whether such an action can be based on allegedly false answers to a…”
Danko v. Redway Enter., Inc., 757 A.2d 1064 (Conn. 2000). · cites it 2× “as may have been necessarily incurred by the other party by reason of such untrue pleading”); accord General Statutes § 52-99. Practice Book § 9-14 provides: “Persons may be joined as defendants against whom the right to relief is alleged to exist in the alternative, although a…”
Dorfman v. Smith (Conn. 2022). · cites it 14× “[the] allegation[s]’’ in the complaint, in violation of General Statutes § 52-99. The plaintiff’s attorney then noticed the defendant’s deposition to address, in part, the factual basis behind its answer and special defense.”
Dorfman v. Smith, 342 Conn. 582 (Conn. 2022). · cites it 14× “[the] allegation[s]’’ in the complaint, in violation of General Statutes § 52-99. The plaintiff’s attorney then noticed the defendant’s deposition to address, in part, the factual basis behind its answer and special defense.”
Dorfman v. Liberty Mut. Fire Ins. Co. (Concurrence & Dissent) (Conn. App. Ct. 2024). · cites it 7× “General Statutes § 52-99 to address that issue specifi- cally.”
Dorfman v. Smith (Conn. 2022). · cites it 3× “15 General Statutes § 52-99 provides: ‘‘Any allegation or denial made with- out reasonable cause and found untrue shall subject the party pleading the same to the payment of such reasonable expenses, to be taxed by the court, as may have been necessarily incurred by the other…”
DiSpazio v. Pacapelli, 231 Conn. App. 589 (Conn. App. Ct. 2025). · cites it 2× “In support of their argument that the court could not award sanctions if the plaintiffs had probable cause, the plaintiffs state that ‘‘[t]he trial court appears to order attorney’s fees pursuant to Practice Book § 10-5 and [General Statutes] § 52-99.’’ Practice Book § 10-5 and…”
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