Conn. Gen. Stat. » Title 53a — PENAL CODE · Chapter 951 — Penal Code: Statutory Construction; Principles of Criminal Liability
Connecticut General Statutes

Conn. Gen. Stat. § 53a-4 (2026)

Saving clause

✓ current as of May 2026
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The provisions of this chapter shall not be construed as precluding any court from recognizing other principles of criminal liability or other defenses not inconsistent with such provisions.

(1969, P.A. 828, S. 4.)

Cited. 209 C. 75; 227 C. 32; 229 C. 60; 233 C. 174; 236 C. 266.

Cited. 23 CA 615; 30 CA 470; Id., 527; 32 CA 224; 36 CA 680.

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Notes of Decisions
Cited in 26 cases (2 in the last 5 years), 1988–2025 · leading case: State v. Courchesne, 998 A.2d 1 (Conn. 2010).
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State v. Courchesne, 998 A.2d 1 (Conn. 2010). · cites it 17× “]); Commission to Revise the Criminal Statutes, Penal Code Comments, Conn. Gen. Stat. Ann. § 53a-4 (West 2007), comment, p.”
Valeriano v. Bronson, 546 A.2d 1380 (Conn. 1988). · cites it 17× “The petitioner points to General Statutes § 53a-4 12 of the code, entitled “Saving clause,” and argues that this provision maintains the viability of the “year and a day” rule.”
State v. DeJesus, 953 A.2d 45 (Conn. 2008). · cites it 10× “General Statutes § 53a-4. [9] It will provide some degree of flexibility and common law creativity on the part of a court that is confronted with an evidentiary question that is not covered, either explicitly or implicitly, by the [c]ode.”
State v. Lee, 640 A.2d 553 (Conn. 1994). · cites it 18× “The defendant contends that the saving clause of General Statutes § 53a-4 17 and the court’s inherent power to protect its own processes provide authority for judicial adoption of the proposed defense.”
State v. Miranda, 878 A.2d 1118 (Conn. 2005). · cites it 12× “, 214-17; (2) recognition by the courts of such a duty and the criminal consequences of its breach is permitted by General Statutes § 53a-4; id., 219-20; (3) this duty has been recognized as applying, in addition to biological and adoptive parents and legal guardians, to other…”
State v. Miranda, 715 A.2d 680 (Conn. 1998). · cites it 15× “Although this notion “does not appear in haec verba in the penal code, that lacuna is not determinative in this case, because [General Statutes] § 53a-4 of the code provides: ‘The provisions of this chapter shall not be construed as precluding any court from recognizing other…”
State v. Walton, 630 A.2d 990 (Conn. 1993). · cites it 7× “” Unlike our penal code, however, neither the Arizona criminal statutes nor the New York penal law contains a savings clause comparable to General Statutes § 53a-4. Moreover, contrary to the assertion of the dissent, we do not fashion an additional substantive offense by…”
State v. Coltherst, 820 A.2d 1024 (Conn. 2003). · cites it 3× “General Statutes § 53a-4 provides: “The provisions of this chapter shall not be construed as precluding any court from recognizing other principles of criminal liability or other defenses not inconsistent with such provisions.”
State v. Messler, 562 A.2d 1138 (Conn. App. Ct. 1989). · cites it 7× “General Statutes § 53a-4 provides: “The provision of this chapter shall not be construed as precluding any court from recognizing other principles of criminal liability or other defenses not inconsistent with such provisions.”
State v. Sawyer, 904 A.2d 101 (Conn. 2006). · cites it 2× “See Connecticut General Statutes § 53a-4. It will provide some degree of flexibility and common law creativity on the part of a court that is confronted with an evidentiary question that is not covered, either explicitly or implicitly, by the Code.”
State v. Lee, 620 A.2d 1303 (Conn. App. Ct. 1993). · cites it 4× “While our penal code does not preclude our courts from recognizing defenses in addition to those created by statute; General Statutes § 53a-4; State v. Woods, 23 Conn.”
State v. Diaz, 679 A.2d 902 (Conn. 1996). · cites it 2× “If you conclude that the defendant was a member of the conspiracy, as charged in the fifth count of the information, beyond a reasonable doubt and that the murder was within the scope of and in furtherance of this conspiracy, then each and every member of that conspiracy would…”
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