Foreclosure Attorney Hub

Understand the judgment. Know the dates that matter.

Strict foreclosure vs foreclosure by sale:
what your Connecticut judgment means

A Connecticut court ends a foreclosure case in one of two main ways: a judgment of strict foreclosure, which sets law days, or a judgment of foreclosure by sale, which sets an auction. Your court papers say which. This page explains both in plain words from the statutes and the court’s own rules, and lists the questions you can bring to a foreclosure lawyer.

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Which judgment is in your papers?

Choose the line that matches what the court entered. This explains the stage; it does not assess your case.

What this stage means, in plain words

Judgment of strict foreclosure

The court sets a law day for the owner and, after it, law days for anyone else with a claim on the property, in reverse order of priority. Paying all sums the court found due, including costs, on or before your law day means title vests absolutely in you, the defendant who paid. If no one redeems, the right to redeem is cut off when the last law day passes and title becomes unconditional in the lender. There is no sale: the lender takes title, and where the property is worth more than the debt, the debt is satisfied by the property itself. You can ask an attorney to read the judgment with you and explain the amount and the dates in it.

This guide explains the two judgment types and the questions you can ask. If you would rather speak with an attorney, choose your county and decide which firm to contact.Find an attorney

01 · Judgment of strict foreclosure

The court sets a law day for the owner and, after it, law days for anyone else with a claim on the property, in reverse order of priority. Paying all sums the court found due, including costs, on or before your law day means title vests absolutely in you, the defendant who paid. If no one redeems, the right to redeem is cut off when the last law day passes and title becomes unconditional in the lender. There is no sale: the lender takes title, and where the property is worth more than the debt, the debt is satisfied by the property itself. You can ask an attorney to read the judgment with you and explain the amount and the dates in it.

02 · Law day set

The law day is the last day the owner can redeem, which means paying everything the court found due, including costs. Law days for later lienholders follow, in reverse order of priority. Within ten days of the judgment the lender must send a certified letter to any owner who has not appeared in the case, stating the terms of the judgment and the risk of losing the property on the law day. You can ask an attorney what the judgment requires of you and by when.

03 · Law day passed

Once the last law day passes without redemption, the lender’s title becomes absolute and the right to possession follows; the judgment holds off ejectment until the day after the last assigned law day. A strict foreclosure judgment can be reopened only before title becomes absolute, except in a short window by agreement of every party. You can ask an attorney what the judgment means for your situation and what they can review.

04 · Judgment of foreclosure by sale

Instead of law days, the court orders the property sold at a public sale on a day it fixes. It appoints a committee, an attorney from the court’s list, to run the sale, and a disinterested appraiser who values the property under oath; on motion by the owner of the equity, the court appoints a second appraiser. Any party may ask for a sale by written motion; the court decides. You can ask an attorney what a sale would mean for the equity in your home.

05 · Sale day

Under the statewide standing orders the sale takes place at noon on the property, with inspection from 10 a.m. to noon. A bidder must bring a deposit of 10 percent of the value the court found, by bank or certified check; the lender’s deposit is waived. Your rights in the property end when the court confirms the sale, not on the auction day. You can ask an attorney what happens between the auction and the court’s approval.

06 · Sale approved, money into court

After the court approves the sale, the committee, as the person appointed to make the sale, signs the deed that transfers title to the buyer. The sale money is paid into court, and a supplemental judgment names each party entitled to the money and the amount. If the money does not cover the debt, the court can enter a deficiency judgment. If the property sold for less than the appraisal, one-half of the difference between the appraised value and the sale price must be credited to the debt before the rest can be collected, but that credit applies only to the debt of the party on whose motion the sale was ordered. You can ask an attorney whether it applies in your case, which turns on who asked for the sale. You can ask an attorney whether any money may be due to you or from you.

I’m not sure

A judgment of strict foreclosure sets law days; a judgment of foreclosure by sale sets a sale date. You do not need to identify it yourself before asking a firm about a consultation; you can describe what you received and ask what documents the firm needs.

The stage descriptions follow the Judicial Branch’s research guide,1 Practice Book § 23-17,2 the Uniform Standing Orders34 and General Statutes §§ 49-14 to 49-28.56789 Official court information: Connecticut Judicial Branch’s homeowner FAQs. Just received the papers? Start with the first 15 days.

Understand the rules

What the statutes and standing orders say

Two figures from the court’s own rules, the factors the court weighs, and six terms you will see in a judgment.

Foreclosure by sale: the bidder’s deposit

10% of the court-found value
Standing order

Uniform Standing Orders for Foreclosure by Sale, JD-CV-79, revised July 2025. Paid by bank or certified check when the bidder registers; waived for the lender.3

Strict foreclosure: the deficiency motion window

30 days after the redemption period ends
Statute

Any party may move for a deficiency judgment within thirty days after the time limited for redemption expires; the hearing comes no sooner than fifteen days after filing. General Statutes § 49-14.8

Connecticut is a title-theory state: the lender holds legal title from the day the mortgage is signed, and the owner keeps the equity of redemption, the right to get title back by paying what is owed. A foreclosure is the court cutting off that right.1 Strict foreclosure is the rule and foreclosure by sale the exception: any party may move for a sale in writing, and the court decides.5 The Appellate Court has held that refusing a sale when the property’s value substantially exceeds the lien is an abuse of that discretion.10 The difference matters because a strict foreclosure has no sale: the lender takes title, and where the property is worth more than the debt, the debt is satisfied by the property itself and the lender is entitled to nothing more. A sale converts the property into money, and the court then determines the parties’ rights in the funds.1

Since 2015 there is a third path, foreclosure by market sale, for a first mortgage on an owner-occupied home that is worth less than the debt, and only when the owner and the lender both agree. The home is listed with a broker the owner chooses, the court approves the purchase contract, and later lienholders get right-of-first-refusal law days within thirty days of the judgment. Neither side has to agree to it, and refusing is not bad faith.11

What the court weighs before ordering a sale

  • A written motion for a sale by any party
  • The court’s own discretion
  • Value that substantially exceeds the lien being foreclosed
01 · Law day

What it isThe date a strict foreclosure judgment sets as the last day a party can redeem. The owner’s comes first; later lienholders follow, in reverse order of priority.

ExampleA judgment entered in March sets the owner’s law day in May and a second-mortgage holder’s the day after.

AskWhat is my law day, and what amount does the judgment say redeems?

02 · Redemption

What it isPaying all sums the court found due, plus taxed costs, before the deadline. Title then vests in the defendant who paid, subject to any unpaid liens that rank ahead of that defendant.

ExampleAn owner pays the judgment amount and costs on the law day; the lender withdraws the case and the owner keeps the home.

AskWhat is the exact payoff figure, and to whom is it paid?

03 · Committee

What it isThe attorney the court appoints from the clerk’s list of approved attorneys to advertise the sale, hold the inspection and conduct the sale, and to sign the deed once the court approves it.

ExampleThe committee posts the notice on the Judicial Branch site, places the sign 20 to 30 days out, and runs the noon auction.

AskWho is the committee, and how do I reach them about the inspection?

04 · Appraisal

What it isIn a foreclosure by sale the court appoints a disinterested appraiser who values the property under oath and files the report before the sale. On motion by the owner of the equity, the court must appoint a second appraiser.

ExampleThe court’s finding of value sets the 10 percent deposit a bidder must bring.

AskWhat did the appraiser find, and may I see the report?

05 · Supplemental judgment

What it isAfter a sale, the court order that names each party entitled to the proceeds and the amount each receives.7

ExampleThe proceeds are brought into court and paid out under that order; the standing orders tell owners to check with the clerk after the sale about any money distributable to them.

AskIs any money distributable to me, and how do I claim it?

06 · Deficiency judgment

What it isA separate judgment for the gap between the debt and the property’s value, when the property does not cover the debt.8

ExampleAfter a strict foreclosure the lender moves within 30 days of the end of the redemption period; a hearing on the property’s value follows.

AskHas a deficiency motion been filed, and what value will the court use?

The examples are illustrations, not descriptions of any case. Two clarifications: the court’s Foreclosure Mediation Program can take up the assignment of law days and sale dates, along with ways to keep the home or leave it, and it has no application fee.12 And a bankruptcy filing automatically opens a judgment of strict foreclosure as to its law days, unless title has already become absolute; after the bankruptcy stay ends the court sets new law days on an updated debt figure and, if the last appraisal is more than 120 days old, a new appraisal.94 You can ask any firm which of these applies to the judgment in your papers.

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Cannot afford a private attorney? The Judicial Branch homeowner FAQs12 and our free foreclosure help page list official, no-cost resources.

Sources & further reading

  1. Connecticut Judicial Branch Law Libraries: Foreclosure of Mortgages in Connecticut (research guide, 2025 edition). Introduction and Section 1: Connecticut as a title-theory state; strict foreclosure and law days as described in JP Morgan Chase Bank v. Gianopoulos, 131 Conn. App. 15, 21–22 (2011); Section 2: an owner’s rights end on the court’s confirmation of a foreclosure sale, In re Loubier, 6 B.R. 298, 303 (1980); where the property’s value exceeds the debt, a mortgagee taking title has its debt satisfied and is entitled to nothing more, Gruss v. Curry, 132 Conn. 22 (1945), as quoted in National City Mortgage v. Stoecker, 92 Conn. App. 787 (2006). Reviewed September 21, 2026.
  2. Connecticut Practice Book § 23-17(b) (2026), as quoted in the Judicial Branch Law Libraries’ Postjudgment Proceedings in Connecticut Mortgage Foreclosures (2026 edition), Section 3: title vests in a defendant who pays all sums found due plus costs; execution of ejectment is stayed until the day after the last assigned law day. Reviewed September 21, 2026.
  3. Connecticut Judicial Branch: Uniform Standing Orders for Foreclosure by Sale, form JD-CV-79, Rev. 7-25. Orders 1, 2, 6, 7, 8, 9 and 11: committee appointed from the court’s list; certified letter to non-appearing owners within ten days of judgment; disinterested appraiser under oath; sale at 12:00 noon on the premises; inspection 10:00 a.m. to noon; deposit of 10% of the fair market value found by the court, by bank or certified check, waived for the plaintiff; sign placed 20 to 30 days before the sale. Reviewed September 21, 2026.
  4. Connecticut Judicial Branch: Uniform Foreclosure Standing Orders, form JD-CV-104, Rev. 4-26. Order D: certified letter to non-appearing owners within ten days of a judgment of strict foreclosure stating the terms and the law-day risk; Order F: after bankruptcy relief, a new law day is set on an updated affidavit of debt, with a new appraisal when the last finding of value is more than 120 days old. Reviewed September 21, 2026.
  5. Conn. Gen. Stat. § 49-24 (2025): a lien or mortgage may be foreclosed by a decree of sale instead of strict foreclosure, on the written motion of any party, at the court’s discretion. The section’s annotations record the Appellate Court’s statement that in Connecticut strict foreclosure is the rule and foreclosure by sale the exception (121 Conn. App. 554). Reviewed September 21, 2026.
  6. Conn. Gen. Stat. §§ 49-25 and 49-26 (2025): when a sale is decreed the court appoints a person to make the sale, fixes the day, and appoints one disinterested appraiser who appraises under oath, and on the motion of the owner of the equity of redemption appoints a second; after the court ratifies the sale, the conveyance by that person vests title in the purchaser. Reviewed September 21, 2026.
  7. Conn. Gen. Stat. §§ 49-27 and 49-28 (2025): sale proceeds are brought into court and applied under a supplemental judgment naming the parties entitled and the amounts; a plaintiff who buys need bring in only the excess over its judgment debt, interest and costs; when proceeds fall short, a deficiency may be entered, but if the property sold for less than the appraisal, the party on whose motion the sale was ordered must credit one-half of the difference to its debt before collecting the balance; the rule does not apply in a foreclosure by market sale. Reviewed September 21, 2026.
  8. Conn. Gen. Stat. § 49-14 (2025): any party may move for a deficiency judgment within thirty days after the time limited for redemption has expired; the short-calendar hearing is held not less than fifteen days after filing; the court establishes a valuation and renders judgment for the difference, if any. Reviewed September 21, 2026.
  9. Conn. Gen. Stat. § 49-15 (2025): a judgment of strict foreclosure may be opened and modified on written motion for cause, but not after title has become absolute except by agreement of every appearing party and later interest holder within four months of judgment or thirty days after title became absolute, whichever is later; a mortgagor’s bankruptcy petition opens the judgment automatically as to its law days unless title has already become absolute. Reviewed September 21, 2026.
  10. Voluntown v. Rytman, 27 Conn. App. 549, 555 (1992), as quoted in source 1: when the value of the property substantially exceeds the lien being foreclosed, refusing to order a foreclosure by sale is an abuse of discretion. Reviewed September 21, 2026.
  11. Conn. Gen. Stat. §§ 49-24a to 49-24g (2025), foreclosure by market sale, in force since January 1, 2015: applies to a first mortgage on an owner-occupied one-to-four-family home where the debt exceeds the appraised value; requires the mutual consent of mortgagor and mortgagee, and refusal is not bad faith (§ 49-24b); licensed appraisal (§ 49-24c); listing with a broker chosen by the owner (§ 49-24d); court judgment approving the contract (§ 49-24f); right-of-first-refusal law days scheduled within thirty days of judgment (§ 49-24g). Reviewed September 21, 2026.
  12. Connecticut Judicial Branch: Foreclosure Homeowner FAQs. Question 25: mediation covers ways to keep the home, ways to leave it, and “assignment of law days and sale dates”; General Information questions 6 and 7: no application fee and no attorney required for the Foreclosure Mediation Program. Reviewed September 21, 2026.

General information only, not legal advice. Foreclosure Attorney Hub is a directory, not a law firm. This page does not determine rights, deadlines, eligibility or legal options, and no outcome is promised. Court rules, standing orders and statutes can change; rely on official sources and the papers in your own case for current requirements. A licensed Connecticut attorney can advise you about your circumstances. Using this website does not create an attorney-client relationship.

Foreclosure Attorney Hub · Editorial review, not legal review · Published and reviewed September 21, 2026