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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marks omitted.) Gilmore v. Pawn King, Inc., 313 Conn.
         535, 542–43, 98 A.3d 808 (2014).
            In our view, § 8-267 (3) (B) unambiguously provides
         that it was the defendant’s enforcement of building
         codes that triggered the act’s protections. A plain read-
         ing of § 8-267 (3) (B) reveals that a displaced person
         is one ‘‘who . . . moves as the direct result of code
         enforcement activities . . . .’’ As this court has pre-
         viously recognized when considering who is a ‘‘dis-
         placed person’’ under the act, there will always be an
         underlying cause that initially brought about the need
         for building code enforcement. See Dukes v. Durante,
         192 Conn. 207, 221, 471 A.2d 1368 (1984) (‘‘[w]hether
         condemnation results from burst pipes or falling ceil-
         ings, the result is an unsound structure’’). We do not
         read this definitional statute to concern itself with the
         specific root cause of how a building became uninhabi-
         table. Any number of reasons might lead a municipality
         to exercise its police powers to protect its citizenry by
         ordering residents to move out of a building, rendering
         them ‘‘displaced persons’’ for purposes of the act. See
         id. (‘‘[i]ndeed, in those buildings where displacement
         is necessary, the nomenclature of the violations is irrele-
         vant’’). The act’s definition of ‘‘displaced person’’ does
         not concern itself with fault but instead focuses on the
         status of the tenants. These clear, threshold determina-
         tions do not require further inquiry into why unhabitable
         conditions came to displace the building’s residents.
            As applied to the present case, it is undisputed that
         a third party’s arson left the plaintiff’s property in a state
         that violated the defendant’s building codes. Indeed, the
         plaintiff acknowledges that the defendant’s emergency
         intervention was necessary in the aftermath of the fire.
         It is also undisputed that less than one hour after the
         fire occurred, the defendant issued a document titled
         ‘‘Notice Violation/Emergency and Order to Abate,’’
         which instructed all residents to vacate their units
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