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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plaintiff contends that § 8-270a permits it to assert, in
support of its application to discharge the lien, that the
plaintiff cannot be liable under § 47a-7 because it did
not cause the fire that displaced the tenants. In
response, the defendant contends that the plaintiff can-
not apply to discharge the lien because § 8-270a makes
clear that a § 47a-7 argument is available only as an
affirmative defense to a civil action filed by a municipal-
ity to recover from a landlord payment the municipality
has made on behalf of displaced residents. We agree
with the defendant.
As we did in part I of this opinion, we exercise plenary
review over the trial court’s interpretation of §§ 8-268,
8-270 and 8-270a. The plain meaning rule continues to
guide this portion of our analysis. See General Statutes
§ 1-2z; Gilmore v. Pawn King, Inc., supra, 313 Conn.
542–43. In addition, we note that, ‘‘if possible, the com-
ponent parts of a statute should be construed harmoni-
ously in order to render an overall reasonable
interpretation.’’ (Internal quotation marks omitted.)
Board of Education v. State Board of Education, 278
Conn. 326, 333, 898 A.2d 170 (2006). However, we can-
not go so far as to import additional provisions into
statutory schemes in an effort to create greater harmony
or consistency than the terms of the statute permit.
See, e.g., Battersby v. Battersby, 218 Conn. 467, 470,
590 A.2d 427 (1991) (‘‘When language used in a statute
is clear and unambiguous, its meaning is not subject
to modification or construction. . . . Absent ambigu-
premises with his consent, in which case such duty shall be the responsibility
of the tenant; (3) keep all common areas of the premises in a clean and
safe condition; (4) maintain in good and safe working order and condition
all electrical, plumbing, sanitary, heating, ventilating and other facilities and
appliances and elevators, supplied or required to be supplied by him; (5)
provide and maintain appropriate receptacles for the removal of ashes,
garbage, rubbish and other waste incidental to the occupancy of the dwelling
unit and arrange for their removal; and (6) supply running water and reason-
able amounts of hot water at all times and reasonable heat . . . .’’
November 5, 2024 CONNECTICUT LAW JOURNAL Page 13

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