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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was not defective so as to deprive the trial court of
jurisdiction. The requirement imposed on the plaintiff
by the court in this matter simply is not found in the
statutory language or our case law. The notice to quit
set forth specific instances of conduct by the defendant,
such as his assorted arrests, his use of illegal narcotics,
his allowing others to consume narcotics, his threats
to a neighbor, and his allowing unauthorized occupants
to reside in the premises. Furthermore, the notice to
quit also generally informed the defendant that such
conduct was done in violation of the lease agreement,
the rules and regulations of the plaintiff, his statutory
obligations as a tenant pursuant to § 47a-11, and consti-
tuted a nuisance. It is not required that the plaintiff
identify the specific lease provisions or statutes that
such conduct violated. See General Statutes § 47a-15.
It is ‘‘inconceivable’’ that the defendant was not aware
of the conduct that formed the basis of the termination
of his lease. Southland Corp. v. Vernon, 1 Conn. App.
439, 452–53, 473 A.3d 318 (1984). Accordingly, we con-
clude that the court improperly determined that the
notice to quit was invalid or defective.
II
The defendant claims, as an alternative ground for
affirming the judgment of the trial court, that the plain-
tiff’s notices did not comply with federal notice require-
ments, and, as a result, the court lacked subject matter
jurisdiction. Specifically, he argues that the plaintiff’s
notices were insufficient under federal law because
they informed the defendant only that he was entitled
to a grievance hearing if such a proceeding was appro-
priate. We are not persuaded.
‘‘When a defendant is a tenant of federally subsidized
housing, federal law must be followed in addition to
state law.’’ (Internal quotation marks omitted.) Milford
Redevelopment & Housing Partnership v. Glicklin,
supra, 228 Conn. App. 603; see also Presidential Village,
0, 0 CONNECTICUT LAW JOURNAL Page 23

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