Freccia v. Freccia, 232 Conn. App. 353 (2025)

Citation: Freccia v. Freccia, 232 Conn. App. 353 (2025)
Parent Document: Freccia v. Freccia, 232 Conn. App. 353 (2025)
Jurisdiction: Connecticut (state)
Effective Date: 2025-05-06
Original Source: https://www.courtlistener.com/opinion/10513133/freccia-v-freccia/ ↗

Full Text

2,640 chars

ing, notify the tenant that the tenant must quit posses-
sion or occupancy of the premises on a specified date,
include the address of the property, and state the reason
or reasons for the notice to quit possession or occu-
pancy using the statutory language or words of similar
import. General Statutes § 47a-23 (b).
‘‘It follows that, for purposes of determining whether
it had subject matter jurisdiction over [a] . . . sum-
mary process action, [a trial] court . . . need[s] to
determine only whether the notice to quit issued by [a]
plaintiff complied with § 47a-23. . . .
‘‘[T]o establish subject matter jurisdiction, the court
must determine that it has the power to hear the general
class [of cases] to which the proceedings in question
belong.’’ (Citations omitted; footnote omitted; internal
quotation marks omitted.) Housing Authority v. Ste-
vens, 209 Conn. App. 569, 577–79, 267 A.3d 927, cert.
denied, 343 Conn. 907, 273 A.3d 234 (2022).
Ordinarily, ‘‘[o]nly in [the] most exceptional circum-
stances can and will [an appellate] court consider a
claim, constitutional or otherwise, that has not been
raised and decided in the trial court. . . . A claim that
a court lacks subject matter jurisdiction, however, may
be raised at any time during the proceedings, including
for the first time on appeal.’’ (Citation omitted; footnote
omitted; internal quotation marks omitted.) Mangiafico
v. Farmington, 331 Conn. 404, 429–30, 204 A.3d 1138
(2019). Accordingly, we are not persuaded that the
defendants’ claim is not reviewable.
Second, we turn to the merits of the claim, which,
consistent with the principles set forth previously in
this opinion, may be distilled to the issue of whether
the plaintiff strictly complied with § 47a-23.14 We are
14
General Statutes § 47a-23 provides in relevant part: ‘‘(a) When the owner
or lessor, or the owner’s or lessor’s legal representative, or the owner’s or
lessor’s attorney-at-law, or in-fact, desires to obtain possession or occupancy
of any land or building, any apartment in any building, any dwelling unit,
any trailer, or any land upon which a trailer is used or stands, and (1) when
0, 0 CONNECTICUT LAW JOURNAL Page 31

Other Sections in This Document (93)

Full Text