Connecticut General Statutes
Conn. Gen. Stat. § 53a-96 (2026)
Unlawful restraint in the second degree: Class A misdemeanor
✓ current as of May 2026
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(a) A person is guilty of unlawful restraint in the second degree when he restrains another person.
(b) Unlawful restraint in the second degree is a class A misdemeanor.
(1969, P.A. 828, S. 98.)
Cited. 178 C. 600; 188 C. 372; 191 C. 604; 197 C. 413; Id., 602; 206 C. 100; 211 C. 672; 224 C. 397; 231 C. 195. Because an unlawful restraint involves the restriction of another person's movements with the intent to interfere substantially with that person's liberty, the crime of unlawful restraint is a specific intent crime. 287 C. 509.
Cited. 9 CA 656; 19 CA 396; 29 CA 524; 30 CA 281; 31 CA 497; 46 CA 486.
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Notes of Decisions
Cited in 71
cases (4 in the last 5 years), 1979–2026 · leading case: State v. Sanseverino, 969 A.2d 710 (Conn. 2009).
State v. Sanseverino, 969 A.2d 710 (Conn. 2009). “Second, the state contends that, if it elects not to retry the defendant for kidnapping, it nevertheless is entitled to a judgment of conviction of unlawful restraint in the second degree under General Statutes § 53a-96 as a lesser included offense of kidnapping in the first…”
State v. Salamon, 949 A.2d 1092 (Conn. 2008). “) General Statutes § 53a-94 (a). By contrast, a person commits the crime of unlawful restraint in the second degree "when he restrains another person.”
State v. Lopez, 889 A.2d 254 (Conn. App. Ct. 2006). “The juiy found each defendant guilty of robbery in the first degree in violation of General Statutes § 53a-134 (a) (4), unlawful restraint in the second degree in violation of General Statutes § 53a-96 (a), and larceny in the sixth degree in violation of General Statutes §§…”
State v. Cotton, 825 A.2d 189 (Conn. App. Ct. 2003). “, appeals from the judgment of conviction, rendered after a jury trial, of unlawful restraint in the second degree in violation of General Statutes § 53a-96 (a), kidnapping in the first degree in violation of General Statutes § 53a-92 (a) (2) (A), sexual assault in the third…”
Luurtsema v. Comm'r of Corr., 12 A.3d 817 (Conn. 2011). “We note, however, that in addition to that twenty-five year sentence, had the petitioner not been convicted of kidnapping, he might have been subject to an additional sentence if the prosecution had sought and the jury had convicted him of the lesser included charge of unlawful…”
State v. Faria, 703 A.2d 1149 (Conn. App. Ct. 1997). “One element of General Statutes § 53a-92 (a) (2) (A) is that the actor have the intent to “inflict physical injury upon [another person] or violate or abuse him sexually .”
State v. Jordan, 186 A.3d 1 (Conn. 2018). “In connection with that 2012 incident, the victim was convicted of misdemeanor assault in the third degree in violation of **285 General Statutes § 53a-61 (a) (1), 8 unlawful restraint in the second degree in violation of General Statutes § 53a-96, 9 and criminal trespass in the…”
State v. Daugaard, 647 A.2d 342 (Conn. 1994). “The defendant was acquitted of kidnapping in the first degree in violation of General Statutes § 53a-92 (a) (2) (A), and its lesser included offenses of kidnapping in the second degree in violation of General Statutes § 53a-94, and unlawful restraint in the second degree in…”
State v. Davis, 767 A.2d 137 (Conn. App. Ct. 2001). “from the judgment of conviction, rendered after a jury trial, of sexual assault in the first degree in violation *623 of General Statutes § 53a-70 (a) (l), 1 sexual assault in the second degree in violation of General Statutes § 53a-71 (a) (l), 2 risk of injury to a child in…”
State v. Pentland, 994 A.2d 147 (Conn. 2010). “On January 19, 2005, the defendant *308 pleaded guilty under the Alford doctrine 3 to two counts of reckless endangerment in the second degree in violation of General Statutes § 53a-64 4 and one count of unlawful restraint in the second degree in violation of General Statutes §…”
Franko v. Comm'r of Corr., 139 A.3d 798 (Conn. App. Ct. 2016). “General Statutes § 53a-95. 14 If the petitioner had been tried for unlawful restraint in the second degree, the state would have had the burden of proving beyond a reasonable doubt that the petitioner restrained the victim.”
State v. Vass, 469 A.2d 767 (Conn. 1983). “The defendant’s claim that he was entitled to a charge of unlawful restraint in the second degree; General Statutes § 53a-96; 14 must also fail, but for another reason.”
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