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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

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

Other Sections in This Document (198)

Full Text

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plated by § 8-267 (3) (B), which defines a ‘‘displaced
       person’’ in relevant part as ‘‘any person who so moves
       as the direct result of code enforcement activities
       . . . .’’ The parties’ dispute centers on whether the
       plaintiff’s tenants constituted displaced persons under
       the act, even though the fire was not the plaintiff’s fault.
       The defendant argues that the trial court erred because
       the relocation assistance that a city provides and a
       landlord is liable for under the act ‘‘does not turn on
       what started the causal chain that ultimately led to the
       residents’ displacement’’ but focuses on whether a city
       had to engage in code enforcement activities. The plain-
       tiff responds that the trial court properly recognized
       that the act does not apply to the present case because
       a third party’s arson, not the defendant’s enforcement
       of the local building code, directly caused the residents’
       displacement. The plaintiff contends that the arsonist
       caused the tenants’ displacement because it was the
       fire and smoke that first prompted residents to leave
       the building, and the defendant posted notice of code
       violations after that.
          These statutory questions arise out of the plaintiff’s
       application under § 49-51 to discharge the defendant’s
       lien. A lien’s validity is typically a ‘‘mixed question of
       fact and law.’’ PNC Bank, N.A. v. Kelepecz, 289 Conn.
       692, 697, 960 A.2d 563 (2008). If the underlying facts
       are undisputed, as they are here, however, the lien’s
       validity presents an issue of law, hinging upon the inter-
       pretation of the applicable statutes. See id. Our review
       is therefore plenary. We interpret statutes pursuant to
       General Statutes § 1-2z, which directs us ‘‘to consider
       the text of the statute itself and its relationship to other
       statutes. If, after examining such text and considering
       such relationship, the meaning of such text is plain and
       unambiguous and does not yield absurd or unworkable
       results, extratextual evidence of the meaning of the
       statute shall not be considered.’’ (Internal quotation
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