§ 966

Citation: § 966
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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constitutional rights were also implicated . . . not
       every deviation from the strict requirements of either
       statutes or regulations warrants dismissal of an
       action for summary process. When good cause for ter-
       mination of a lease has clearly been shown, and when
       notices of termination have been sent in strict compli-
       ance with statutory timetables, a landlord should not
       be precluded from pursuing summary eviction pro-
       ceedings because of hypertechnical dissection of the
       wording of the notices that he has sent.’’ (Citation omit-
       ted; emphasis added.) Id.
          In the present case, the reasons underlying the termi-
       nation of the lease contained in the plaintiff’s notices
       constituted good cause for terminating the lease. See
       id., 145–46. The defendant does not argue to the con-
       trary. Instead, he baldly asserts that the notices were
       insufficient with respect to the information contained
       therein regarding the matter of a grievance hearing. He
       has not provided us any authority to support his claim
       that, as a result of this claimed deficiency regarding
       the availability of a grievance hearing, the court lacked
       subject matter jurisdiction over the summary process
       action.17 In light of our Supreme Court’s reasoning in
       Jefferson Garden Associates v. Greene, supra, 202 Conn.
       128, and the general presumption in favor of jurisdic-
       tion, we conclude that the plaintiff’s lack of strict com-
       pliance in this matter did not render its notices defective
       so as to deprive the trial court of subject matter jurisdic-
       tion.
          17
             We note that a landlord’s failure to comply with the federal statutory
       requirements has been held to be enforceable in other procedural contexts.
       See Poole v. Housing Authority, 202 F. Supp. 3d 617, 623–25 (W.D. La.
       2016) (failure to comply with federal housing statutes resulted in summary
       judgment rendered in favor of tenant); see also Samuels v. District of
       Columbia, 770 F.2d 184, 193–98 (D.C. Cir. 1985) (private enforcement of
       housing statute and regulations available under 42 U.S.C. § 1983); Conway
       v. Housing Authority, 239 F. Supp. 2d 593, 597–99 (W.D.N.C. 2002) (noting
       that Congress intended to give public housing tenant right to enforce griev-
       ance procedures through private right of action pursuant to 42 U.S.C. § 1983).
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