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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charge the defendant’s lien for the sake of making the
provisions of the act, in its view, harmonious, and to
generate consistent outcomes across cases with similar
facts. Although courts should prioritize a harmonious
reading of different statutory provisions, we cannot set
aside the plain meaning of the terms the legislature
provided. See, e.g., Battersby v. Battersby, supra, 218
Conn. 470. Further, because § 8-270a and relevant por-
tions of §§ 8-268 and 8-270 were promulgated as part of
the same public act, we must assume that the legislature
intentionally omitted the use of a § 8-270a ground from
the act’s provisions involving liens. See Asylum Hill
Problem Solving Revitalization Assn. v. King, 277
Conn. 238, 256, 890 A.2d 522 (2006) (‘‘[when] a statute,
with reference to one subject contains a given provi-
sion, the omission of such provision from a similar
statute concerning a related subject . . . is significant
to show that a different intention existed’’ (internal
quotation marks omitted)).4
4
We note that, even if we determined that the statutory language in
question is in any way ambiguous, the relevant legislative history indicates
that the legislature passed § 8-270a and the lien provisions in §§ 8-268 and
8-270 with full awareness that landlords would still be liable to municipalities
in the first instance for relocation costs in circumstances under which
landlords were not at fault.
At the beginning of legislative debate on the matter, Representative
Thomas P. Brunnock asked, ‘‘if a tenant was the one who had caused the
disrepair of the property to result in building code enforcement violations,
would the landlord still be ultimately liable for the relocation costs if the
relocation was necessitated by those building code violations?’’ 25 H.R. Proc.
Pt. 16, 1982 Sess., pp. 5370–71. Representative Paul J. Garavel responded,
‘‘I believe that is true.’’ Id., p. 5371. Representative Robert Farr openly
questioned this during ongoing discussions of the amendments: ‘‘[Represen-
tative] Brunnock properly pointed out in some cases the tenants may have
caused it, and perhaps we need an amendment to exclude those cases
. . . .’’ Id., p. 5375. Despite these conversations, P.A. 82-399 was passed,
with its proponents stressing that, without its provisions, the statute ‘‘has
put an absolutely intolerable burden [on] the cities in our state.’’ Id., p.
5390, remarks of Representative Gerard B. Patton. As an example of this,
Representative Brunnock referenced the expenses the city of Waterbury
faced when a fire required relocating thirty families. Id., pp. 5377–78.
Page 16 CONNECTICUT LAW JOURNAL November 5, 2024

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