Thomas Lumpkin, Jr., sued Nutmeg State Financial Credit Union seeking damages for alleged violations of the UCC and RISFA. The trial court granted summary judgment for the credit union, ruling that Lumpkin’s claims were time-barred by General Statutes § 52-585, which imposes a one-year limitation period for actions seeking forfeiture under penal statutes.
The plaintiff appealed, arguing that the timeliness of his claims should be governed by either the four-year limitation period in Article 2 of the UCC or the three-year statute of limitations for tort claims under General Statutes § 52-577.
In a per curiam opinion, the Supreme Court concluded that the trial court incorrectly applied § 52-585. The court held that because §§ 42a-9-625 and 36a-785 are not penal statutes, the one-year limitation period is inapplicable.
Guided by its decision in the companion case of Connex Credit Union v. Madgic, 354 Conn. 459 (2026), the court determined that the three-year limitation period in § 52-577 is the most suitable statute of limitations for claims brought under §§ 42a-9-625 and 36a-785.
The court reversed the trial court’s judgment and remanded the case for further proceedings, instructing the lower court to apply the three-year statute of limitations to Lumpkin’s claims.