§ 1-2z

Citation: § 1-2z
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 ten-
         ants indeed constituted displaced persons under the
         act, we must analyze whether, in response to the defen-
         dant’s lien, the plaintiff can raise its claim that it did
         not cause the property damage that resulted in the
         tenants’ displacement.
                                       I
           The first question we must resolve is whether the
         plaintiff’s tenants were ‘‘displaced persons,’’ as contem-
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