How long does a party have to sue on a written contract in Connecticut?
Six years: no action for an account, or on any simple or implied contract, or on any contract in writing, shall be brought but within six years after the right of action accrues (§ 52-576(a)), with three years after becoming legally capable for a person legally incapable when the right accrued (§ 52-576(b)). A separate section sets three years for an action 'founded upon any express contract or agreement which is not reduced to writing, or of which some note or memorandum is not made in writing and signed by the party to be charged' (§ 52-581(a)), so the six-year answer is for a contract in writing. Neither section applies to a cause of action governed by article 2 of title 42a (§§ 52-576(c), 52-581(b)), that is, contracts for the sale of goods, and § 52-576 does not apply to actions on judgments. Article 2's own period is four years: 'An action for breach of any contract for sale must be commenced within four years after the cause of action has accrued' (§ 42a-2-725 (1), as the Supreme Court quotes it in Connex Credit Union v. Madgic and the Appellate Court in Palkimas v. Quilli). Whether a contract is one for sale turns on its predominant purpose, because '[t]o determine whether a contract including both goods and services is governed by the [UCC], the court must determine whether the dominant factor or essence of the transaction is the sale of the materials or the services'; on that test the Appellate Court held a contract to build, paint and install custom cabinets, with all materials provided by the owner, 'primarily one for services, not goods', so that 'the UCC does not govern the plaintiff’s action' (Palkimas). The six years runs from accrual as the chapter defines it: fraudulent concealment defers accrual to discovery (§ 52-595), and time the defendant is out of the state is excluded, up to seven years (§ 52-590).
The trap
A contract for goods is not on the six-year clock: § 52-576(c) sends it to Article 2, and Article 2's limitation section is not in our published statutes, so § 42a-2-725 reaches a reader only through the Connecticut decisions quoting § 42a-2-725, which print subsection (1) 'in relevant part' and elide what follows; whatever else the section provides was not read. Nor does Palkimas supply the period for a services contract, concluding only that 'the UCC does not govern the plaintiff’s action'. A CUTPA claim pleaded alongside the contract claim has its own period: an action under § 42-110g 'may not be brought more than three years after the occurrence of a violation' (§ 42-110g(f)). Connecticut divides oral contracts by performance, not by form: § 52-581 reaches only executory contracts, and an oral contract one party has fully performed falls under § 52-576's six years (Tierney v. American Urban Corp., 1976; John H. Kolb & Sons, Inc. v. G & L Excavating, Inc., Conn. App. 2003, cert. denied). "A contract is executory when neither party has fully performed its contractual obligations and is executed when one party has fully performed its contractual obligations." Whether and how far a Connecticut contract may shorten the six-year period was not verified.
15 authorities
- statuteConn. Gen. Stat. § 52-576enactment date not established
The words that state the rule
No action for an account, or on any simple or implied contract, or on any contract in writing, shall be brought but within six years after the right of action accrues, except as provided in subsection (b) of this section.
- statuteConn. Gen. Stat. § 52-576enactment date not established
The words that state the rule
The provisions of this section shall not apply to actions upon judgments of any court of the United States or of any court of any state within the United States, or to any cause of action governed by article 2 of title 42a.
- statuteConn. Gen. Stat. § 52-581enactment date not established
The words that state the rule
No action founded upon any express contract or agreement which is not reduced to writing, or of which some note or memorandum is not made in writing and signed by the party to be charged therewith or his agent, shall be brought but within three years after the right of action accrues. (b) This section shall not apply to causes of action governed by article 2 of title 42a.
- statuteConn. Gen. Stat. § 42-110genactment date not established
The words that state the rule
An action under this section may not be brought more than three years after the occurrence of a violation of this chapter.
- statuteConn. Gen. Stat. § 52-576enactment date not established
The words that state the rule
Any person legally incapable of bringing any such action at the accruing of the right of action may sue at any time within three years after becoming legally capable of bringing the action.
The words that state the rule
Since the plaintiff’s performance was alleged to have been completely executed, § 52-576 established the applicable limitation period.
The words that state the rule
If §§ 6005 [now § 52-576] and 6010 [now § 52-581] are to be construed to make a harmonious body of law, it is necessary to restrict the latter, as was suggested in Baker v. Lee . . . [ 52 Conn. 145 ], to executory contracts.
- case76 Conn. App. 599John H. Kolb & Sons, Inc. v. G & L Excavating, Inc.Conn. App.decided 2003read it at the source ↗
The words that state the rule
A contract is executory when neither party has fully performed its contractual obligations and is executed when one party has fully performed its contractual obligations.
- case76 Conn. App. 599John H. Kolb & Sons, Inc. v. G & L Excavating, Inc.Conn. App.decided 2003read it at the source ↗
The words that state the rule
It is well established, therefore, that the issue of whether a contract is oral is not dispositive of which statute applies. Thus, the defendant’s argument that § 52-581 automatically applies to the oral contract between the parties is incorrect. The determinative question is whether the contract was executed.
- statuteConn. Gen. Stat. § 52-595enactment date not established
The words that state the rule
If any person, liable to an action by another, fraudulently conceals from him the existence of the cause of such action, such cause of action shall be deemed to accrue against such person so liable therefor at the time when the person entitled to sue thereon first discovers its existence.
- statuteConn. Gen. Stat. § 52-590enactment date not established
The words that state the rule
In computing the time limited in the period of limitation prescribed under any provision of chapter 925 or this chapter, the time during which the party, against whom there may be any such cause of action, is without this state shall be excluded from the computation, except that the time so excluded shall not exceed seven years.
- caseConn. S.C. 21171 (April 28, 2026)Connex Credit Union v. MadgicConn.decided 2026
The words that state the rule
General Statutes § 42a-2-725 (1) provides in relevant part: “An action for breach of any contract for sale must be commenced within four years after the cause of action has accrued. . . .”
- caseConn. App. A.C. 48078 (April 21, 2026)Palkimas v. QuilliConn. App.decided 2026
The words that state the rule
General Statutes § 42a-2-725 provides in relevant part: “(1) An action for breach of any contract for sale must be commenced within four years after the cause of action has accrued. . . .”
- caseConn. App. A.C. 48078 (April 21, 2026)Palkimas v. QuilliConn. App.decided 2026
The words that state the rule
“[t]o determine whether a contract including both goods and services is governed by the [UCC], the court must determine whether the dominant factor or essence of the transaction is the sale of the materials or the services”
- caseConn. App. A.C. 48078 (April 21, 2026)Palkimas v. QuilliConn. App.decided 2026
The words that state the rule
Therefore, we conclude that the court correctly determined that the contract was primarily one for services, not goods, and that determination was supported by the parties’ written agreement and their testimony at trial.11 Accordingly, the UCC does not govern the plaintiff’s action, and we reject the defendants’ first claim.
“Defective” means that reading found something to correct. What you are reading is the rule as it stands after that reading.