Where several matters of defense are pleaded, each must refer to the cause of action which it is intended to answer, and be separately stated and designated as a separate defense, as, First Defense, Second Defense, etc. Where the complaint or counterclaim is for more than one cause of action, set forth in several counts, each separate matter of defense should be preceded by a designation of the cause of action which it is designed to meet, in this manner: First Defense to First Count, Second Defense to First Count, First Defense to Second Count, and so on. Any statement of a matter of defense resting in part upon facts pleaded in any preceding statement in the same answer may refer to those facts as thus recited, without otherwise repeating them.
Section 10-51.—Several Special Defenses
Current through August 12, 2025 (2026 Practice Book edition) · Last verified July 9, 2026
In one sentenceWhen a defendant pleads more than one special defense, each defense must be stated separately, labeled First Defense, Second Defense, and so on, and matched to the specific count or cause of action it answers.
Full Text of Section 10-51
Amendment History
(P.B. 1978-1997, Sec. 165.)
Plain-English Summary
This rule governs how a defendant organizes multiple special defenses in an answer. Each matter of defense must refer to the cause of action it answers, be stated separately, and carry its own label — First Defense, Second Defense, and so on.
When the complaint or counterclaim contains more than one count, each defense must also identify which count it meets, using labels like First Defense to First Count, Second Defense to First Count, First Defense to Second Count. A defense that relies in part on facts already stated in an earlier part of the same answer can refer back to those facts instead of repeating them.
Frequently Asked Questions
How do you label multiple special defenses in a Connecticut answer?
Each one gets its own numbered label, such as First Defense, Second Defense, and so on, and each must be stated separately from the others.
What if the complaint has more than one count?
Each defense must be tied to the count it answers, using a label like First Defense to First Count or Second Defense to First Count, so the reader knows which count each defense meets.
Can a special defense refer back to facts already stated earlier in the answer?
Yes. A defense resting in part on facts pleaded in a preceding part of the same answer may refer to those facts as already recited, without repeating them.
Source & verification. The section text is reproduced verbatim from the
official Connecticut Practice Book (Conn. Practice Book § 10-51). Prescribed by the Judges of the Superior Court of Connecticut (Conn. Gen. Stat. Section 51-14). The plain-English summary is original and written by us. Last verified July 9, 2026. ·
Official source
Also known as: multiple special defenses format CTlabeling special defenses ConnecticutFirst Defense Second Defense pleadingspecial defense to specific counthow to organize an answer with defenses