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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ings, the result is an unsound structure’’). We do not
read this definitional statute to concern itself with the
specific root cause of how a building became uninhabi-
table. Any number of reasons might lead a municipality
to exercise its police powers to protect its citizenry by
ordering residents to move out of a building, rendering
them ‘‘displaced persons’’ for purposes of the act. See
id. (‘‘[i]ndeed, in those buildings where displacement
is necessary, the nomenclature of the violations is irrele-
vant’’). The act’s definition of ‘‘displaced person’’ does
not concern itself with fault but instead focuses on the
status of the tenants. These clear, threshold determina-
tions do not require further inquiry into why unhabitable
conditions came to displace the building’s residents.
As applied to the present case, it is undisputed that
a third party’s arson left the plaintiff’s property in a state
that violated the defendant’s building codes. Indeed, the
plaintiff acknowledges that the defendant’s emergency
intervention was necessary in the aftermath of the fire.
It is also undisputed that less than one hour after the
fire occurred, the defendant issued a document titled
‘‘Notice Violation/Emergency and Order to Abate,’’ which
instructed all residents to vacate their units because
the building was ‘‘[u]nfit for [h]uman [o]ccupancy.’’ Once
the defendant issued that order, the residents became
displaced as a ‘‘direct result of code enforcement activi-
ties’’ under § 8-267 (3) (B). This is the most sensible
reading in light of the legislatively declared purpose of
the act, which includes ‘‘establish[ing] a uniform policy
for the fair and equitable treatment of persons displaced
. . . by building code enforcement activities . . . .’’
General Statutes § 8-266. Even though the arson destroyed
the property, there was some danger that residents of
the building would seek to return if they had no other
place for shelter. It was the defendant’s code enforce-
ment that directly resulted in the displacement of the
tenants.
November 5, 2024 CONNECTICUT LAW JOURNAL Page 11

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