Connecticut
Connecticut Debt Collection Laws: Wage Garnishment, Statute of Limitations, and Repossession
Independently fact-checked against primary sources (last audited August 12, 2026). · 8 primary sources cited on this page. How we verify our legal content

A collector cannot start taking money from your paycheck in Connecticut the moment you miss a payment. For ordinary consumer debt, the creditor has to sue you, win a judgment, and then obtain a wage execution from the court before your employer withholds anything. That sequence is where most garnishments are actually decided, because the large majority happen through a default judgment entered when the person being sued never filed an answer. If you take one action from this page, answer any lawsuit you are served with, even if you believe the debt is too old or is not yours.
Wage Garnishment in Connecticut
Connecticut's garnishment cap, C.G.S. 52-361a(f), limits a wage execution to the lesser of two figures: 25% of your disposable earnings for the week, or the amount by which your disposable earnings exceed 40 times the higher of the federal minimum wage or Connecticut's own minimum fair wage. Because Connecticut's minimum wage is far above the federal $7.25 floor, the state figure is the one that actually controls.
The protected amount is always 40 times whatever Connecticut's minimum fair wage is at the time, so it moves every year. Under C.G.S. 31-58(j), the Labor Commissioner announces an inflation adjustment to the minimum fair wage each October 15, and the new rate takes effect the following January 1. At the $16.94 rate effective January 1, 2026, the 40-times threshold is $677.60 a week; wages at or below that amount cannot be touched at all, and above it, no more than 25% can be taken. Confirm the current rate with the Connecticut Department of Labor before relying on the dollar figure, because the formula outlasts any specific number.
Connecticut has no head-of-household exemption on top of this formula; the 40-times-minimum-wage floor is the protective mechanism for every debtor. Only one wage execution can be enforced against a given employee's wages at a time. If more than one creditor has obtained a wage execution, they are satisfied in the order presented to the employer, not simultaneously.
Firing protection: the seven-garnishment threshold
Federal law only protects an employee from being fired over a garnishment for one debt; a second garnishment on a different debt carries no federal firing protection. Connecticut sets its own, more generous line. Under C.G.S. 52-361a(j), an employer cannot discipline, suspend, or discharge an employee because of a wage execution unless the employer has been served with more than seven wage executions against that employee within a calendar year. An employer who violates this rule is liable for the employee's lost earnings and benefits and can be ordered to reinstate the employee.
Bank Account Protections
Connecticut protects a $1,000 «any property» wildcard exemption under C.G.S. 52-352b, which a debtor can apply to money in a bank account as well as other property.
Connecticut also gives you an automatic bank-account shield that does not depend on you filing anything. Under C.G.S. 52-367b(c)(2), when a bank execution is served on a financial institution, the institution «shall leave in the judgment debtor's account» the amount of electronic direct deposits, not to exceed $1,000, that are readily identifiable as wages, provided those deposits were made during a look-back period of the two months before the execution was served. If no such deposits were made in that window, or if the readily identifiable funds come to less than $1,000, the institution must still leave «the lesser of the account balance or one thousand dollars in the aggregate» as exempt under C.G.S. 52-352b(18).

The same subsection requires the institution to leave the full amount of electronic direct deposits that are readily identifiable as exempt federal benefits, a list that includes Social Security retirement, survivors' and disability benefits, supplemental security income, veterans' benefits, Railroad Retirement Board and federal Office of Personnel Management benefits, unemployment compensation exempt under 52-352b, and Title IV-D child support payments. C.G.S. 52-367b(c)(3) adds that you keep full and customary access to whatever the institution leaves in the account.
Federal benefits carry a separate, better-established protection regardless of state law. Social Security, VA, and similar federal benefits that arrive by direct deposit are automatically shielded for the trailing two months of deposits under 31 CFR Part 212, and the bank applies that protection without you filing anything. Benefits paid by paper check and later deposited do not get this automatic treatment and must be claimed as exempt through the court.
Statute of Limitations on Debt in Connecticut
Connecticut does not run a clean written-versus-oral split the way many states do.
| Debt type | Limitations period | Statute |
|---|---|---|
| Written contract, account, or simple contract | 6 years | C.G.S. 52-576 |
| Executory oral contract | 3 years | C.G.S. 52-581 |
| Credit card debt | 6 years (treated as an account/simple contract) | C.G.S. 52-576 |
The 3-year oral-contract period is narrower than it looks. Connecticut case law limits it to executory oral contracts, meaning agreements where performance is still owed on one or both sides. An oral contract that one party has already fully performed generally falls under the 6-year period in 52-576 instead. In practice, most consumer debt, including credit-card balances, is treated as an account or simple contract carrying the 6-year period rather than the 3-year one.
The revival rule for purchased debt
Connecticut has a targeted anti-revival statute that applies specifically to purchased consumer debt, meaning debt bought by a debt buyer or collection agency rather than debt still held by the original creditor. Under C.G.S. 36a-814, a creditor or consumer collection agency that purchased the debt cannot initiate a lawsuit when it knows, or reasonably should know, that the statute of limitations has expired. Once the limitations period has run, the statute goes further: «notwithstanding any other provision of law,» any later payment toward the debt, or any oral or written affirmation of it, does not extend the limitations period. This rule does not change how revival works for debt that is still held by the original creditor; that question rests on common-law acknowledgment doctrine that was not independently researched this session, so treat original-creditor revival as an open question rather than assume the same anti-revival rule applies.
Time-barred does not mean the debt disappears. A collector may still contact you about an old debt, but federal Regulation F, 12 CFR 1006.26, bars a debt collector from suing or threatening to sue on a debt once the statute of limitations has expired. Credit reporting runs on its own separate clock, roughly seven years, regardless of the limitations period.
What Debt Collectors Can and Cannot Do
The federal Fair Debt Collection Practices Act governs third-party collectors operating in Connecticut. They cannot use false, deceptive, or misleading statements, including misrepresenting the amount or legal status of a debt, and cannot threaten action they cannot legally take or do not intend to take, 15 U.S.C. 1692e. Regulation F adds specific limits on call frequency and requires collectors to provide validation information.
Connecticut's own rule reaches further than the federal one in a way that matters to a lot of readers. C.G.S. 36a-646 provides that «no creditor shall use any abusive, harassing, fraudulent, deceptive or misleading representation, device or practice to collect or attempt to collect any debt.» C.G.S. 36a-645(2) defines «creditor» as any person to whom a consumer debtor owes a debt arising in the ordinary course of that person's business, or any person the debt is assigned to. That definition reaches the original creditor, which the FDCPA generally does not, so a hospital, a card issuer, or a utility collecting its own account is bound by the Connecticut rule even where the federal statute does not apply to it.
C.G.S. 36a-648 supplies the private remedy. A creditor who violates 36a-646 or 36a-805 is liable to the person for actual damages, plus, if that person is an individual, whatever additional damages the court awards up to $1,000, plus the costs of a successful action and, in the court's discretion, a reasonable attorney's fee. Two limits go with it: the creditor escapes liability if it proves by a preponderance of the evidence that the violation was unintentional and resulted from a bona fide error despite reasonable procedures, and the action must be brought within one year of the date the violation occurs, C.G.S. 36a-648(c) and (d). That one-year clock is short, so a Connecticut claim is worth raising early rather than after a collection suit has run its course.
Licensed consumer collection agencies sit under a separate statute. Connecticut licenses them through the Department of Banking, and C.G.S. 36a-805 bars a long list of specific practices, including adding a post-charge-off collection charge the debtor is not contractually liable for, holding money collected past the remittance deadline, and failing to give the required written disclosure when collecting on a debt that is already beyond the statute of limitations.
Car Repossession Rules
Connecticut enacted the Uniform Commercial Code's self-help repossession rule at C.G.S. 42a-9-609: after default, a secured party may take possession of collateral without judicial process, as long as it can do so without a breach of the peace.

Connecticut layers unusually detailed protections on top of that baseline for motor vehicles, under C.G.S. 36a-785. If the repossession happens without the buyer's knowledge, the holder must notify local police, or state police, within 2 hours. A creditor can choose to give an optional 10-day pre-repossession cure notice; if it does and the buyer does not cure, the creditor may retake the vehicle without any further redemption right. If the creditor does not give that notice, it must hold the vehicle in-state for 15 days, during which the buyer can redeem it by paying the unaccelerated amount due plus reasonable repossession and storage costs. The holder also owes a written statement of account within 3 days, and there is a 60-day window to retrieve personal property left in a repossessed vehicle.
Filing a Chapter 7 bankruptcy petition is not, by itself, a default. C.G.S. 36a-785(a) states that the filing of a petition in bankruptcy under 11 U.S.C. Chapter 7 by a retail buyer of a motor vehicle, or that buyer's status as a debtor in bankruptcy, is not a default under the retail installment contract and is not a ground for repossessing the vehicle. Read the carve-out narrowly: it names Chapter 7, and it does not name Chapter 13.
Connecticut also bars most deficiency judgments after a vehicle repossession and resale. The only exception is for motor vehicles or boats whose aggregate cash price exceeded $4,000, and even then the deficiency is measured against a prima facie fair market value based on published trade-in and retail guides as of the repossession date, not necessarily the actual resale price.
Connecticut's repossession statutes do not separately regulate electronic starter-interrupt or «kill switch» devices, so there is no Connecticut-specific consent or advance-notice requirement before a lender uses one. A lender that uses such a device is still bound by the breach-of-the-peace limit in 42a-9-609 and by the notice, redemption, resale, and deficiency rules in 36a-785. Those protections are not something a buyer can sign away: under C.G.S. 36a-785(j), no act or agreement of the retail buyer before or at the time the contract is made, and no statement in the contract itself, waives subsections (c) through (i) of that section.
Servicemembers get an additional federal layer. For an installment contract entered into before military service, the Servicemembers Civil Relief Act, 50 U.S.C. 3952, requires a court order before the property can be repossessed for a pre-service breach.
If You Are Being Garnished or Sued in Connecticut
Work the problem in this order:
- Answer the lawsuit. A default judgment is how most Connecticut garnishments start. Filing an answer, even a simple one disputing the amount, forces the creditor to prove its case and often opens the door to a payment arrangement.
- Check the garnishment math. Compare what is being withheld against the 25%/40-times-minimum-wage formula, using the minimum wage in effect right now rather than a figure you read last year. If more than one execution has been served, only one should be enforced at a time.
- Look at what the bank left in your account. On a bank execution, C.G.S. 52-367b(c)(2) requires the institution to leave up to $1,000 of readily identifiable wage deposits, or at minimum the lesser of your balance or $1,000, plus identifiable federal benefits, without you filing anything.
- If you get a repossession notice, use your window. Depending on whether the creditor gave a cure notice, you may have up to 15 days to redeem the vehicle by paying the past-due amount plus costs.
- Ask whether the debt is time-barred. Most Connecticut consumer debt carries a 6-year period, longer than the 3-year rule that applies only to executory oral contracts. Raise the statute of limitations as a defense in your answer; the court will not raise it for you.
- Watch for a debt buyer suing on an old debt. If a collection agency that bought your debt sues after the limitations period has run, C.G.S. 36a-814 may bar the suit outright.
- Consider a Connecticut claim of your own. If a creditor used abusive or deceptive collection tactics, C.G.S. 36a-648 allows actual damages plus up to $1,000 more and attorney's fees, but only within one year of the violation.
- Consider bankruptcy if the debt is unmanageable. Filing triggers an automatic stay that stops garnishment immediately, and Connecticut's exemptions apply inside bankruptcy too.
Overwhelmed by debt? Get a free bankruptcy consultation
Bankruptcy can stop foreclosure, wage garnishment, and creditor calls, and which debts you can clear and what property you keep depend on your state's exemptions. Get a free, confidential consultation with a bankruptcy attorney to understand your options. There is no obligation.
Information last verified on 2026-09-02. This article has not yet been reviewed by a licensed lawyer.

Related Resources
- Debt Collection Laws by State
- How to Stop Wage Garnishment
- Statute of Limitations on Debt
- Can Social Security Be Garnished?
- Connecticut Statute of Limitations
- Connecticut Bankruptcy Laws
Last updated: 2026-09-02.
More Connecticut Laws
Frequently Asked Questions
How much of my paycheck can be garnished in Connecticut?
The lesser of 25% of your disposable earnings for the week, or the amount your disposable earnings exceed 40 times the higher of the federal or Connecticut minimum wage, under C.G.S. 52-361a(f). The protected floor is 40 times the state minimum wage in effect at the time, and that rate re-indexes every January 1 under C.G.S. 31-58(j). At the $16.94 rate effective January 1, 2026, wages up to $677.60 a week are fully protected.
Can I be fired for a wage garnishment in Connecticut?
Not for the first several garnishments. C.G.S. 52-361a(j) bars discipline or discharge over a wage execution unless your employer has been served with more than seven wage executions against you in a calendar year, well beyond the federal one-debt protection.
How much money in my bank account is protected in Connecticut?
C.G.S. 52-367b(c)(2) requires the bank to automatically leave up to $1,000 of electronic direct deposits readily identifiable as wages from the prior two months. If there are no such deposits, or they total less than $1,000, the bank must still leave the lesser of your account balance or $1,000 as exempt under C.G.S. 52-352b(18), plus the full amount of identifiable federal benefit deposits. You do not have to file anything for this protection to apply.
What is the statute of limitations on credit card debt in Connecticut?
Six years, C.G.S. 52-576, because credit-card debt is generally treated as an account or simple contract rather than the narrower 3-year executory-oral-contract category in 52-581.
Does making a payment restart the statute of limitations in Connecticut?
For debt bought by a debt buyer or collection agency, no. C.G.S. 36a-814 says that once the limitations period has expired, a later payment or acknowledgment does not extend it. Whether the same rule applies to debt still held by the original creditor was not confirmed this session.
Can I sue a Connecticut creditor for abusive collection tactics?
Yes. C.G.S. 36a-646 bars any creditor, including an original creditor the FDCPA may not reach, from using abusive, harassing, fraudulent, deceptive or misleading collection practices, and C.G.S. 36a-648 allows actual damages, up to $1,000 in additional damages for an individual, plus costs and a reasonable attorney's fee. The action must be brought within one year of the violation.
Does the repo company have to notify police before taking my car in Connecticut?
Yes, in most cases. C.G.S. 36a-785 requires notification of local or state police within 2 hours of a motor-vehicle repossession the buyer did not witness.
Can I be sued for the difference after my car is repossessed and sold in Connecticut?
Usually not. Connecticut bars most deficiency judgments after a vehicle repossession, with an exception only for motor vehicles or boats whose cash price exceeded $4,000.
Updates
Removed an unsupported claim that Connecticut regulates electronic vehicle kill switches, replaced an incorrect "unverified" hedge with the automatic $1,000 bank-account exemption in C.G.S. 52-367b(c)(2), added Connecticut’s own creditor collection-practices law and private remedy (C.G.S. 36a-646 and 36a-648), narrowed the repossession bankruptcy carve-out to Chapter 7, and restated the garnishment floor as 40 times the current minimum wage so the dollar figure cannot silently go stale.
Independently fact-checked against the cited primary sources
The Law Behind This Article
This article rests on the statutory provisions below, held in our own legal record and retrieved from the official source. Tap a section to read the operative text.
Connecticut General Statutes, Title 52 (Civil Actions), Chapter 906
§ 52-361aExecution on wages after judgment.In forcecited in 2 of our articles
(a) Application. If a judgment debtor fails to comply with an installment payment order, the judgment creditor may apply to the court for a wage execution. The application shall contain the judgment creditor's or the judgment creditor's attorney's statement setting forth the particulars of the installment payment order and of the judgment debtor's failure to comply. The application shall be accompanied by a fee of one hundred five dollars payable to the clerk of the court for the administrative costs of complying with the provisions of this section which fee may be recoverable by the judgment creditor as a taxable cost of the action. (b) Issuance. On receipt of the application, a clerk of the Superior Court shall issue a wage execution against the judgment debtor, directed to a levying officer, to enforce payment of the judgment. (c) Contents.
Official text (excerpt) · last checked 2026-09-02 · Read the full text in our law library · Verify at cga.ct.gov
Cited in 22 court opinions in our collectionLatest citing opinion in our collection: 2023
In the courts (editorial summary, independently checked):Hartford Postal Employees Credit Union v. Rosemond (1994) held that the power to modify a wage execution under Section 52-361a(h) does not include power to vacate it, and that ruling on a modification motion requires evidence, not argument alone. Herzig v. Horrigan (1994) noted subsection (g) permits wage executions served on the state.
Opinions citing this section in our collection:
- In re Dean (Supreme Court of Connecticut 1998, 246 Conn. 183)“…gment creditor must pursue another approach to enforcement. General Statutes § 52-361a (a) provides for wage garnishment as an…”
- Hartford Postal Employees Credit Union, Inc. v. Rosemond (Connecticut Appellate Court 1994, 33 Conn. App. 395)✓A credit union's wage execution withheld about $80 a week until the trial court wiped it out entirely on the debtor's motion to modify; the court held the power to modify under section 52-361a(h) does not include the power to vacate, and reversed.
- Cotto v. United Technologies Corp. (Supreme Court of Connecticut 1999, 251 Conn. 1)“…eneral Statutes § 51-247a (where employee serves as juror); General Statutes § 52-361a (j) (where employee becomes subject to…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Bankruptcy in Connecticut (2026): Exemptions & Means Test
Connecticut General Statutes, Title 36a (The Banking Law of Connecticut), Chapter 669
§ 36a-785(Formerly Sec. 42-98). Foreclosure.In force
(a) Repossession. When the retail buyer is in default in the payment of any sum due under the retail installment contract or installment loan contract, or in the performance of any other condition that such contract requires the retail buyer to perform, or in the performance of any promise, the breach of which is by such contract expressly made a ground for the retaking of the goods, the holder of the contract may retake possession of such goods, provided the filing of a petition in bankruptcy under 11 USC Chapter 7 by a retail buyer of a motor vehicle, or such retail buyer's status as a debtor in bankruptcy, shall not be considered a default of a retail installment contract or ground for repossession of such motor vehicle. Unless the goods can be retaken without breach of the peace, the goods shall be retaken by legal process, provided nothing contained in this section shall be construed to authorize a violation of the criminal law. In the case of repossession of any motor vehicle without the knowledge of the retail buyer, the local police department shall be notified of such repossession not later than two hours after repossession.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at cga.ct.gov
Cited in 23 court opinions in our collectionLatest citing opinion in our collection: 2023
Opinions citing this section in our collection:
- Connex Credit Union v. Thibodeau (Connecticut Appellate Court 2021, 208 Conn. App. 861)“…nding that the plaintiff complied with RISFA, specifically, General Statutes § 36a-785 (e), and provided the defendant with a…”
- Sikorsky Financial Credit Union, Inc. v. Butts (Supreme Court of Connecticut 2015)“…arguments, the amicus argues that the repossession statute; General Statutes § 36a-785; pursuant to which the plaintiff brough…”
- Small v. Going Forward, Inc. (Supreme Court of Connecticut 2007, 281 Conn. 417)“…ram” for government funded housing units [emphasis added]); General Statutes § 36a-785 (c) (The holder of an installment sales…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 36a-814Initiation of cause of action for purchased debt prohibited when statute of limitations has expired. Limitations period not extended by payment or affirmation.In force
(a) For the purposes of this section, “creditor” has the same meaning as in section 36a-645. (b) No creditor or consumer collection agency that purchased debt shall initiate a cause of action to collect the debt owed by a consumer debtor when such creditor or consumer collection agency knows or reasonably should know that the applicable statute of limitations on such cause of action has expired. (c) Notwithstanding any other provision of law, when the applicable statute of limitations on a cause of action to collect debt owed by a consumer has expired, any subsequent payment toward or oral or written affirmation of the debt owed by the consumer shall not extend the limitations period within which the creditor or consumer collection agency that purchased the debt may bring the cause of action.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at cga.ct.gov
Connecticut General Statutes, Title 52 (Civil Actions), Chapter 926
§ 52-576Actions for account or on simple or implied contracts.In forcecited in 2 of our articles
(a) 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. (b) 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. (c) 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.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at cga.ct.gov
Cited in 391 court opinions in our collectionLatest citing opinion in our collection: 2026
Opinions citing this section in our collection:
- R.A. Civitello Co. v. City of New Haven (Connecticut Appellate Court 1986, 6 Conn. App. 212)“…barred by the six year statute of limitations contained in General Statutes § 52-576. 2 The city also moved for partial sum…”
- Wynn v. Metropolitan Property & Casualty Insurance (Connecticut Appellate Court 1993, 30 Conn. App. 803)“…was barred by the six year contract statute of limitations, General Statutes § 52-576. 1 The plaintiff commenced this action…”
- Bellemare v. Wachovia Mortgage Corp. (Connecticut Appellate Court 2006, 94 Conn. App. 593)“…the statute of limitations applicable to contract actions, General Statutes § 52-576, permits suit within six years of the a…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Connecticut Statute of Limitations: Filing Deadlines by Case Type
§ 52-581Action on oral contract to be brought within three years.In force
(a) 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.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at cga.ct.gov
Cited in 90 court opinions in our collectionLatest citing opinion in our collection: 2024
Opinions citing this section in our collection:
- Mac's Car City, Inc. v. DeNigris (Connecticut Appellate Court 1989, 18 Conn. App. 525)“…r a limited purpose, and that the first count was barred by General Statutes § 52-581. 2 On April 7,1988, the trial court…”
- Avon Meadow Condominium Ass'n v. Bank of Boston Connecticut (Connecticut Appellate Court 1998, 50 Conn. App. 688)“…tiffs argue that (1) the three year statute of limitations, General Statutes § 52-581, does not apply to an agreement where t…”
- Suffield Development Associates Ltd. Partnership v. Society for Savings (Supreme Court of Connecticut 1998, 243 Conn. 832)“…ntiffs breach *834 of contract claim was time barred under General Statutes § 52-581; 2 (2) the plaintiffs claim for breach…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Code of Federal Regulations Title 12
§ 1006.26Collection of time-barred debts.In forcecited in 37 of our articles
(a) Definitions. For purposes of this section: (1) Statute of limitations means the period prescribed by applicable law for bringing a legal action against the consumer to collect a debt. (2) Time-barred debt means a debt for which the applicable statute of limitations has expired. (b) Legal actions and threats of legal actions prohibited. A debt collector must not bring or threaten to bring a legal action against a consumer to collect a time-barred debt. This paragraph (b) does not apply to proofs of claim filed in connection with a bankruptcy proceeding.
Official text (excerpt) · last checked 2026-09-02 · Read the full text in our law library · Verify at ecfr.gov
Cited in 3 court opinions in our collectionLatest citing opinion in our collection: 2025
In the courts (editorial summary, independently checked):Hanover v. Real Time Resolutions, Inc. (2024) dismissed FDCPA claims built on 12 CFR 1006.26(b), reasoning it bars only collection of time-barred debts and the loans at issue were not time barred. Raja v. Specialized Loan Servicing, LLC (2025) dismissed a Regulation F claim because nonjudicial foreclosure is not covered by the FDCPA.
Opinions citing this section in our collection:
- Hanover v. Real Time Resolutions, Inc. (District Court, S.D. Ohio 2024)✓A borrower claimed a servicer's letter and billing statement lacked language required by 12 CFR 1006.26(b); the court granted the servicer summary judgment, since the rule only bars collecting time-barred debts and it had already found her HELOC and mortgage enforceable.
- Raja v. Specialized Loan Servicing, LLC (District Court, E.D. Virginia 2025)✓Pro se homeowners alleged a servicer and foreclosure attorneys pursued a time-barred, discharged second mortgage in violation of 12 CFR 1006.26(b); the court dismissed that claim, holding parties carrying out a nonjudicial foreclosure are not FDCPA debt collectors.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Idaho Debt Collection Laws: Garnishment Limits, Debt Deadlines, and Repossession, Maine Debt Collection Laws: Wage Garnishment, Statute of Limitations, and Repossession, Michigan Debt Collection Laws: Wage Garnishment, Statute of Limitations, and Repossession
United States Code Title 15
§ 1692eFalse or misleading representationsIn forcecited in 10 of our articles
A debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of any debt. Without limiting the general application of the foregoing, the following conduct is a violation of this section: The false representation or implication that the debt collector is vouched for, bonded by, or affiliated with the United States or any State, including the use of any badge, uniform, or facsimile thereof. The false representation of— the character, amount, or legal status of any debt; or any services rendered or compensation which may be lawfully received by any debt collector for the collection of a debt. The false representation or implication that any individual is an attorney or that any communication is from an attorney. The representation or implication that nonpayment of any debt will result in the arrest or imprisonment of any person or the seizure, garnishment, attachment, or sale of any property or wages of any person unless such action is lawful and the debt collector or creditor intends to take such action. The threat to take any action that cannot legally be taken or that is not intended to be taken.
Official text (excerpt) · last checked 2026-07-28 · Read the full text in our law library · Verify at uscode.house.gov
Cited in 3,533 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):Courts read Section 1692e through the least sophisticated consumer test. Christ Clomon v. Philip D. Jackson (1993) held that mass-mailed letters bearing an attorney signature, sent without file review, violated subsections (3) and (10); Gonzalez v. Kay (2009) held a back-page disclaimer did not defeat the claim on a motion to dismiss.
Opinions citing this section in our collection:
- Miller v. Wolpoff & Abramson, L.L.P. (Court of Appeals for the Second Circuit 2003, 321 F.3d 292)✓Debt letters went out on law firm letterhead after an attorney reviewed only a file showing the debt was outstanding; the Second Circuit held that merely being told by a client that a debt is overdue is not enough attorney involvement, and vacated summary judgment.
- William C. Lewis v. Acb Business Services, Inc., (96-3093/3498), American Express Travel Related Services Company, Inc. James P. Connors, (96-3498) (Court of Appeals for the Sixth Circuit 1998, 135 F.3d 389)✓A collection letter told the debtor to contact 'M. Hall,' a name no employee at the agency actually used; the Sixth Circuit held the alias was not a false or deceptive means under 1692e(10) because the account had been assigned to a real representative and no harm was shown.
- Gonzalez v. Kay (Court of Appeals for the Fifth Circuit 2009, 577 F.3d 600)✓A law firm collecting a $448.97 phone debt sent an unsigned letter on its letterhead with the disclaimer of attorney review only on the back; the Fifth Circuit held the least sophisticated consumer might think a lawyer was involved and reversed dismissal of the 1692e claim.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Statute of Limitations on Debt: The 50-State Payment-Revival Table, Alabama Debt Collection Laws: Wage Garnishment, Statute of Limitations, and Repossession, Alaska Debt Collection Laws: Wage Garnishment, Statute of Limitations, and Repossession
United States Code Title 50
§ 3952Protection under installment contracts for purchase or leaseIn forcecited in 17 of our articles
After a servicemember enters military service, a contract by the servicemember for— the purchase of real or personal property (including a motor vehicle); or the lease or bailment of such property, may not be rescinded or terminated for a breach of terms of the contract occurring before or during that person’s military service, nor may the property be repossessed for such breach without a court order. This section applies only to a contract for which a deposit or installment has been paid by the servicemember before the servicemember enters military service. A person who knowingly resumes possession of property in violation of subsection (a), or in violation of section 3918 of this title, or who knowingly attempts to do so, shall be fined as provided in title 18, or imprisoned for not more than one year, or both.
Official text (excerpt) · last checked 2026-07-28 · Read the full text in our law library · Verify at uscode.house.gov
Cited in 1 court opinions in our collectionLatest citing opinion in our collection: 2025
Opinions citing this section in our collection:
- Ditech Holding Corporation (United States Bankruptcy Court, S.D. New York 2025)“…d on, or sold during or within a year after active service. 50 U.S.C. §§ 3952, 3953. Claimant states that he re…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Louisiana Debt Collection Laws: Prescription, Garnishment, and Repossession, Maryland Debt Collection Laws: Wage Garnishment, Statute of Limitations, and Repossession, Massachusetts Debt Collection Laws: Wage Garnishment, Statute of Limitations, and Repossession
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Sources and References
- C.G.S. Chapter 906, Wage execution formula and protections (52-361a)(cga.ct.gov).gov
- C.G.S. 52-576, Actions on simple or implied contracts (six years)(cga.ct.gov).gov
- C.G.S. 52-581, Actions on executory oral contracts (three years)(cga.ct.gov).gov
- C.G.S. 36a-814, Purchased consumer debt: suit bar and anti-revival on expired debt(cga.ct.gov).gov
- C.G.S. 42a-9-609, Secured party's right to take possession after default(cga.ct.gov).gov
- C.G.S. 36a-785, Motor vehicle repossession: police notice, cure, and deficiency limits(cga.ct.gov).gov
- 15 U.S.C. 1673, Federal restriction on garnishment (25%/30-times test)(govinfo.gov).gov
- 12 CFR 1006.26, Regulation F prohibition on suits and threats of suit on time-barred debt(ecfr.gov).gov
- C.G.S. 52-367b(c)(2), Bank execution: automatic exemption of up to $1,000 in identifiable wage deposits and full identifiable federal benefits(cga.ct.gov)
- C.G.S. 36a-646, No creditor shall use abusive, harassing, fraudulent, deceptive or misleading collection practices(cga.ct.gov)
- C.G.S. 36a-645, Definitions: 'creditor' includes the original creditor and any assignee(cga.ct.gov)
- C.G.S. 36a-648, Private right of action: actual damages, up to $1,000 additional, costs and fees; bona fide error defense; one-year limit(cga.ct.gov)
- C.G.S. 36a-805, Prohibited practices for licensed consumer collection agencies(cga.ct.gov)
- C.G.S. 31-58(j), Minimum fair wage: annual October 15 announcement effective the following January 1(cga.ct.gov)
- Connecticut Department of Labor, current state minimum wage ($16.94 per hour effective January 1, 2026)(portal.ct.gov)