Conn. Gen. Stat. » Title 54 — CRIMINAL PROCEDURE · Chapter 960 — Information, Procedure and Bail
Connecticut General Statutes

Conn. Gen. Stat. § 54-45a (2026)

Record of grand jury proceedings. Transcripts

✓ current as of May 2026
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(a) In any grand jury proceeding ordered pursuant to the provisions of section 54-45, the official stenographer of the Superior Court or his assistant shall make a record of the proceedings excluding the deliberations, which shall be confidential and filed with the court. Access to the transcript shall be available only to the prosecutorial official or any person accused of crime as a result of the grand jury investigation or the accused person's attorney. The prosecutorial official or the person accused of a crime as a result of such grand jury investigation or the accused person's attorney may obtain a copy of the transcript by paying for it.

(b) The transcript of such proceedings may not be used as evidence in any proceeding against the accused except for the purpose of impeaching a witness, attacking the credibility of a witness or proving inconsistent statements of a witness. The transcript may also be used as evidence in a prosecution for perjury committed by a witness while giving such testimony.

(P.A. 78-289, S. 1; P.A. 80-313, S. 4.)

History: P.A. 80-313 divided section into Subsecs. and reworded provisions.

Cited. 177 C. 677; 181 C. 268; 186 C. 476. Availability and use of grand jury transcripts discussed. 187 C. 281. Cited. 193 C. 350; 194 C. 469; Id., 530; 197 C. 698; 198 C. 644; 200 C. 323; 201 C. 534. Statute governs indicting grand juries and expressly prohibits subsequent use of grand jury testimony. 250 C. 188.

Cited. 10 CA 103.

Transcript may not be used to impeach a grand jury finding of a true bill. 36 CS 141. Cited. 42 CS 10; 45 CS 1.

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Notes of Decisions
Cited in 18 cases, 1979–1999 · leading case: State v. Rivera, 736 A.2d 790 (Conn. 1999).
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State v. Rivera, 736 A.2d 790 (Conn. 1999). · cites it 11× “This revelation has special relevance in light of the fact that General Statutes § 54-45a (b), 10 which governs indicting grand juries, 11 expressly prohibits the subsequent use of such testimony.”
State v. Canady, 445 A.2d 895 (Conn. 1982). · cites it 10× “The long-established secrecy of grand jury proceedings has been invaded to a limited extent by General Statutes § 54-45a 2 and by *283 Practice Book § 609.”
State v. Couture, 482 A.2d 300 (Conn. 1984). · cites it 4× “80-313, § 4, General Statutes § 54-45a was amended. The provision discussed above was unchanged however.”
State v. Burns, 481 A.2d 1077 (Conn. 1984). · cites it 11× “In support of his first claimed error, the defendant argues that the trial court failed to comply with General Statutes § 54-45a 3 which he claims affords a clear legal right to a transcript of testimony at the March 5 hearing.”
State v. Mitchell, 512 A.2d 140 (Conn. 1986). · cites it 4× “General Statutes § 54-45a (b) limited the use of grand jury transcripts to the following: “(b) The transcript of such proceedings may not be used as evidence in any proceeding against the accused except for the purpose of impeaching a witness, attacking the credibility of a…”
State v. Cosgrove, 442 A.2d 1320 (Conn. 1982). · cites it 4× “The fact that the legislature enacted General Statutes § 54-45a, effective October 1, 1978, a date about four months after the grand jury returned the indictment in this case, does not indicate any error on the part of the presiding judge in adhering to our *479 previous…”
State v. Piskorski, 419 A.2d 866 (Conn. 1979). · cites it 2× “1 General Statutes § 54-45a, whiek became effective on October 1, 1978, now provides for a transcript of the proceedings before a grand jury with the exception of the deliberations.”
State v. Talton, 497 A.2d 35 (Conn. 1985). · cites it 2× “” The trial court, correctly noting that it could not make substantive use of the complainant’s grand jury testimony; see General Statutes § 54-45a (b); denied the motion on the ground of relevance but indicated that it would reconsider the request at a later stage in the trial,…”
State v. Douglas, 522 A.2d 302 (Conn. App. Ct. 1987). · cites it 4× “In 1978, General Statutes § 54-45a was enacted in apparent response to Chesney v.”
State v. Ostroski, 518 A.2d 915 (Conn. 1986). · cites it 2× “Although we admit some possible ambiguity as to the scope of the terminology used in that opinion, our careful review of the records and briefs in Ostroski II, as well as the opinion itself, leads us to conclude that the issue of whether the admission to Allen was a fruit of the…”
State v. Vinal, 504 A.2d 1364 (Conn. 1986). · cites it 2× “Under General Statutes § 54-45a (b), 10 however, a grand jury transcript may only be used, in subsequent proceedings against an accused, to challenge the credibility of witnesses and to prove perjury.”
State v. Maldonado, 478 A.2d 581 (Conn. 1984). · cites it 2× “He based his allegations on the notes that the defendant took during the grand jury proceedings.”
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