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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tiff’s actions did not cause the displacement of the
         apartment building’s tenants. In particular, the court
         pointed out that, although §§ 8-268 and 8-270 allow a
         municipality to file a lien to recover relocation costs
         from a landlord, § 8-270a provides that, if a city has
         brought a civil action against a landlord under the act
         to recover displacement costs, ‘‘it shall be an affirmative
         defense for the landlord that the displacement was not
         the result of the landlord’s violation of [General Statutes
         §] 47a-7.’’ The court recognized that the proceeding
         before it was not a civil action brought by the defendant
         but nonetheless ruled that the plaintiff could invoke § 8-
         270a because, otherwise, ‘‘inconsistent outcomes would
         occur even [if the] cases were based on very similar
         facts,’’ and ‘‘[t]he legislature cannot have intended such
         inconsistent, bizarre results.’’ The defendant appealed
         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 defen-
         dant’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 defendant’s
         lien, the plaintiff can raise its claim that it did not cause
         the property damage that resulted in the tenants’ dis-
         placement.
                                       I
           The first question we must resolve is whether the
         plaintiff’s tenants were ‘‘displaced persons,’’ as contem-
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