Milford Redevelopment & Housing Partnership v. Glicklin, 228 Conn. App. 593 (2024)

Citation: Milford Redevelopment & Housing Partnership v. Glicklin, 228 Conn. App. 593 (2024)
Parent Document: Milford Redevelopment & Housing Partnership v. Glicklin, 228 Conn. App. 593 (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-10-15
Original Source: https://www.courtlistener.com/opinion/10136084/milford-redevelopment-housing-... ↗

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termination or eviction. When the PHA is required to
       afford the tenant the opportunity for a grievance hear-
       ing, the notice shall also inform the tenant of the tenant’s
       right to request a hearing in accordance with the PHA’s
       grievance procedure.’’12
          Although the regulations require that the pretermina-
       tion notice inform the tenant of the right to request a
       hearing in accordance with the PHA’s grievance proce-
       dure, they do not require that the notice specify the
       time frame for invoking the grievance process. In the
       present case, the defendant does not claim that she was
       unaware of the plaintiff’s grievance procedure, that the
       procedure did not comply with federal law, or that she
       was unaware of her right to request a hearing before
       an impartial party. Instead, her argument is focused
       on a purported deficiency in the pretermination notice
       based on a requirement that does not exist. Accordingly,
       we reject the defendant’s jurisdictional argument.
                                            B
          The defendant also raises, for the first time in her
       appellate brief, an argument that the plaintiff ‘‘fail[ed] to
       provide a pretermination notice with sufficient factual
       information for [the defendant] to defend against the
       claimed violation of [the policy, which] deprived the
       trial court of subject matter jurisdiction over [the plain-
       tiff’s] action.’’ The defendant cites to 42 U.S.C. § 1437d
       (k) and (l) and General Statutes § 47a-15 for the proposi-
       tion that the plaintiff was required to serve the defen-
       dant with ‘‘a valid pretermination notice informing [her]
       of the basis for the proposed termination of her lease
       . . . .’’ The plaintiff responds that the pretermination
         12
            The defendant does not claim that the pretermination notice was inade-
       quate because it did not expressly tell her that she had the right to request
       a hearing as opposed to referring the defendant to the grievance procedure,
       which she acknowledged receiving when she renewed her lease in 2021.
       See footnote 11 of this opinion.
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