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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ity, the courts cannot read into statutes, by construc-
         tion, provisions that are not clearly stated.’’ (Citation
         omitted; internal quotation marks omitted.)).
            With these principles in mind, we turn to the language
         of the specific provisions of the act at issue, §§ 8-268,
         8-270 and 8-270a. In Public Acts 1982, No. 82-399, §§ 1
         through 3 (P.A. 82-399), the legislature amended §§ 8-
         268 and 8-270, and enacted § 8-270a. The legislature
         amended §§ 8-268 and 8-270 to contain this identical
         language: ‘‘[W]henever any tenant in any dwelling unit
         is displaced as the result of the enforcement of any
         code to which this section is applicable by any town,
         city or borough or agency thereof, the landlord of such
         dwelling unit shall be liable for any payments made by
         such town, city or borough pursuant to this section
         . . . .’’ (Emphasis added.) General Statutes § 8-268 (a);
         accord General Statutes § 8-270 (a); see also P.A. 1982,
         No. 82-399, §§ 1 and 2. Section 3 of P.A. 82-399, now
         codified at § 8-270a, provides in relevant part: ‘‘If any
         landlord fails to reimburse any town, city or borough
         for any payments which the town, city or borough has
         made to any displaced tenant and for which the landlord
         is liable pursuant to section 8-268, as amended by sec-
         tion 1 of this act, or section 8-270, as amended by section
         2 of this act, such town, city or borough may bring a
         civil action against such landlord in the superior court
         . . . for the recovery of such payments . . . . In any
         such action, it shall be an affirmative defense for the
         landlord that the displacement was not the result of
         the landlord’s violation of section 47a-7 . . . .’’
         (Emphasis added.)
            Thus, the legislature has plainly provided that, in the
         first instance, pursuant to §§ 8-268 (a) and 8-270 (a), a
         landlord is liable to the municipality for payments the
         municipality has made to or on behalf of displaced
         residents. Both parties acknowledge that a plain reading
         of these statutes allows municipalities to take at least
Page 14                    CONNECTICUT LAW JOURNAL               November 5, 2024

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