however, a pretermination notice is not required.’’
(Internal quotation marks omitted.) Id., 575–76; see also
Towers v. Kelly, 199 Conn. App. 829, 837, 238 A.3d 732,
cert. denied, 335 Conn. 966, 240 A.3d 281 (2020); see
generally Bridgestone Realty Corp. v. Mendoza, 50
Conn. Supp. 125, 128, 918 A.2d 1064 (2006) (§ 47a-15
exempts landlords from serving pretermination notice
where tenant commits serious nuisance).
A serious nuisance under this statutory scheme may
occur in one of four ways. See Suburban Greater Hart-
ford Realty Management Corp. v. Edwards, 123 Conn.
App. 295, 300, 1 A.3d 1138 (2010). As provided in § 47a-
15, serious nuisance means ‘‘[1] inflicting bodily harm
upon another tenant or the landlord or threatening to
inflict such harm with the present ability to effect the
harm and under circumstances which would lead a
reasonable person to believe that such threat will be
carried out, [2] substantial and wilful destruction of
part of the dwelling unit or premises, [3] conduct which
presents an immediate and serious danger to the safety
of other tenants or the landlord, or [4] using the prem-
ises or allowing the premises to be used for prostitution
or the illegal sale of drugs or, in the case of a housing
authority, using any area within fifteen hundred feet
of any housing authority property in which the tenant
resides for the illegal sale of drugs.’’
In the present case, the plaintiff claimed that Blau’s
conduct toward the plaintiff’s attorney and its towing
contractor constituted a serious nuisance and that Bou-
dreau, in failing to require Blau to conduct herself in
a manner that did not constitute a serious nuisance,
committed a serious nuisance in violation of § 47a-11
(g).8 The plaintiff’s attempt to regain possession of the
8
General Statutes § 47a-11 provides in relevant part that ‘‘[a] tenant shall
. . . (g) conduct himself and require other persons on the premises with
his consent to conduct themselves in a manner that will not disturb his
neighbors’ peaceful enjoyment of the premises or constitute . . . a serious
nuisance, as defined in section 47a-15 . . . .’’
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