also Centrix Management Co., LLC v. Fosberg, 349
Conn. 765, 777–79, 322 A.3d 317 (2024) (discussing equi-
table purpose of § 42-150bb); Aaron Manor, Inc. v.
Irving, 307 Conn. 608, 617–18, 57 A.3d 342 (2013)
(same). ‘‘Stated differently, when a commercial entity
enters into a consumer contract that provides the com-
mercial entity with the contractual right to recover
attorney’s fees, § 42-150bb provides consumers with a
reciprocal statutory right to recover attorney’s fees if
he or she successfully prosecutes or defends an action
or counterclaim.’’ Athena Holdings, LLC v. Marcus,
supra, 476.
Next, we set forth the relevant legal principles regard-
ing summary process and serious nuisance. ‘‘The ulti-
mate issue in a summary process action is the right to
possession. Southland Corp. v. Vernon, 1 Conn. App.
439, 443, 473 A.2d 318 (1984). Summary process is a
statutory proceeding that is intended to be summary
and is designed to provide an expeditious remedy to
the landlord seeking possession.’’ (Internal quotation
marks omitted.) Kenosia Commons, Inc. v. DaCosta,
supra, 161 Conn. App. 673; see also Housing Authority
v. DeRoche, 112 Conn. App. 355, 361, 962 A.2d 904
(2009). General Statutes § 47a-15 provides that, except
for those situations specifically excluded, a landlord
must deliver a pretermination notice to the tenant speci-
fying the alleged violations before proceeding with a
summary process action. See Housing Authority v. Ste-
vens, 209 Conn. App. 569, 575, 267 A.3d 927, cert. denied,
343 Conn. 907, 273 A.3d 234 (2022). The pretermination
notice affords the tenant the opportunity to remedy the
violation and avoid a summary eviction. See id.
Situations involving a serious nuisance are among
those specifically excluded from the pretermination
notice requirement. ‘‘When a landlord elects . . . to
evict based on . . . conduct by the tenant which con-
stitutes a serious nuisance; General Statutes § 47a-15;
0, 0 CONNECTICUT LAW JOURNAL Page 9