Housing Authority v. Cyr, 234 Conn. App. 527 (2025)

Citation: Housing Authority v. Cyr, 234 Conn. App. 527 (2025)
Parent Document: Housing Authority v. Cyr, 234 Conn. App. 527 (2025)
Jurisdiction: Connecticut (state)
Effective Date: 2025-08-26
Original Source: https://www.courtlistener.com/opinion/10659980/housing-authority-v-cyr/ ↗

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recognize the violations and to either cure or defend
          against them. It stated further that ‘‘a clear and concise
          [Kapa] notice must be sent to the defendant describing
          the violations alleged as well as providing the defendant
          with the opportunity to cure.’’ It would appear, there-
          fore, that the court implicitly determined that the Kapa
          notice in the present case lacked sufficient specificity
          as part of its conclusion that it lacked subject matter
          jurisdiction over the plaintiff’s summary process action.
             In Jefferson Garden Associates v. Greene, 202 Conn.
          128, 520 A.2d 173 (1987), our Supreme Court addressed
          the standards by which to test the adequacy of notices
          sent to a defendant in a summary process action, includ-
          ing a Kapa notice. Id., 142–43. Specifically, it explained
          that, ‘‘[i]n order to demonstrate its compliance with the
          notices required for a proper termination, a landlord
          must show that the notices given to the tenant apprised
          her of the information a tenant needs to protect herself
          against premature, discriminatory or arbitrary evic-
          tion.’’ Id., 143. To further this salutary purpose, the
          requirements of § 47a-15 must be construed strictly;
          however, strict construction does not require ritualistic
          compliance with statutory or regulatory mandates. Id.,
          143–44. It further noted that ‘‘judicial appraisal [of the
          sufficiency of a Kapa notice] must reflect the purpose
          that [such a notice was] meant to serve . . . [and] not
          every deviation from the strict requirements of either
          statutes or regulations warrants dismissal of an action
          for summary process. When good cause for termination
          of a lease has clearly been shown, and when notices
          of termination have been sent in strict compliance with
          statutory timetables, a landlord should not be precluded
          from pursuing summary eviction proceedings because
          of hypertechnical dissection of the wording of the
          notices that he has sent.’’ (Citation omitted.) Id., 145;
          see also Josephine Towers, L.P. v. Kelly, 199 Conn.
          App. 829, 839–40, 238 A.3d 732 (§ 47a-15 requirements
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