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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

§ 1-2z

Citation
§ 1-2z
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 plaintiff
       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 viola-
       tions 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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