Connelly v. Housing Authority of New Haven, 213 Conn. 354 (1990)

Citation: Connelly v. Housing Authority of New Haven, 213 Conn. 354 (1990)
Parent Document: Connelly v. Housing Authority of New Haven, 213 Conn. 354 (1990)
Jurisdiction: Connecticut (state)
Effective Date: 1990-01-02
Original Source: https://www.courtlistener.com/opinion/7893844/connelly-v-housing-authority-of... ↗

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Further, as we noted in Russell v. Dean Witter Reynolds, Inc., supra, 179-80, the history of the FTC Act is the lodestar for determining the scope of CUTPA. After a review of cases decided under the FTC Act over its seventy-five year history, and of the standards and statements of the FTC, we were unable to *364discover any instance in which that act has been applied to any act or practice of a local public agency, including a housing authority. We also failed to discover any instance in which the FTC Act has been applied to any landlord because of the breakdown of heat or hot water delivery systems.9 In FTC v. Colgate-Palmolive Co., 380 U.S. 374, 85 S. Ct. 1035, 13 L. Ed. 2d 904 (1965), the United States Supreme Court discussed the history and proper role of the FTC Act, and the issues approximating those pleaded in the present case are conspicuously absent. See Ivey, Barnum & O’Mara v. Indian Harbor Properties, Inc., 190 Conn. 528, 533-36, 539-40, 461 A.2d 1369 (1983). The trial court was correct when it determined that under the Russell rationale, CUTPA did not apply.

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