PPC Realty, LLC v. Hartford, 350 Conn. 347 (2024)

Citation: PPC Realty, LLC v. Hartford, 350 Conn. 347 (2024)
Parent Document: PPC Realty, LLC v. Hartford, 350 Conn. 347 (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-08-12
Original Source: https://www.courtlistener.com/opinion/10266509/ppc-realty-llc-v-hartford/ ↗

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to the Appellate Court, and we transferred the case to
         this court pursuant to General Statutes § 51-199 (c) and
         Practice Book § 65-1.
            The defendant raises only one issue on appeal:
         whether, under the act, it properly filed a lien on the
         plaintiff’s property as a means of facilitating the recov-
         ery of costs from the plaintiff that the defendant
         incurred for relocating residents displaced following
         the defendant’s enforcement of building codes, even if it
         was not the plaintiff’s actions that rendered the building
         uninhabitable. To answer this question, we first con-
         sider whether the plaintiff’s tenants fell under the act’s
         definition of ‘‘displaced persons.’’ See General Statutes
         § 8-267 (3). Because we conclude that the plaintiff’s
         tenants indeed constituted displaced persons under the
         act, we must analyze whether, in response to the defen-
         dant’s lien, the plaintiff can raise its claim that it did
         not cause the property damage that resulted in the
         tenants’ displacement.
                                       I
            The first question we must resolve is whether the
         plaintiff’s tenants were ‘‘displaced persons,’’ as contem-
         plated by § 8-267 (3) (B), which defines a ‘‘displaced
         person’’ in relevant part as ‘‘any person who so moves
         as the direct result of code enforcement activities
         . . . .’’ The parties’ dispute centers on whether the
         plaintiff’s tenants constituted displaced persons under
         the act, even though the fire was not the plaintiff’s fault.
         The defendant argues that the trial court erred because
         the relocation assistance that a city provides and a
         landlord is liable for under the act ‘‘does not turn on
         what started the causal chain that ultimately led to the
         residents’ displacement’’ but focuses on whether a city
         had to engage in code enforcement activities. The plain-
         tiff responds that the trial court properly recognized
         that the act does not apply to the present case because
November 5, 2024         CONNECTICUT LAW JOURNAL                        Page 9

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