accurately identified the owner’s attorney-at-law,” it
could not conclude that the notice failed to comply with
§ 47a-23 (a). Id.
We granted the defendants’ petition for certification
to appeal to determine whether the Appellate Court cor-
rectly so concluded. See Freccia v. Freccia, 352 Conn.
957, 336 A.3d 1250 (2025).6
II
It is well established that, “before a landlord may pur-
sue its statutory remedy of summary process under §
47a-23, the landlord must prove its compliance with
all the applicable preconditions set by state and federal
law . . . .” Jefferson Garden Associates v. Greene, 202
Conn. 128, 143, 520 A.2d 173 (1987). A notice to quit
is one such precondition and, if defective, will deprive
a court of subject matter jurisdiction, except in narrow
circumstances. See, e.g., Bayer v. Showmotion, Inc.,
292 Conn. 381, 388, 973 A.2d 1229 (2009); Bristol v.
Ocean State Job Lot Stores of Connecticut, Inc., 284
Conn. 1, 5, 931 A.2d 837 (2007). Our review of whether a
notice to quit served by a plaintiff effectively conferred
subject matter jurisdiction is plenary. See, e.g., Bayer
v. Showmotion, Inc., supra, 388.
We have explained that “[s]ummary process is a special
statutory procedure designed to provide an expeditious
remedy. . . . It enable[s] landlords to obtain possession
of leased premises without suffering the delay, loss and
expense to which, under the common-law actions, they
might be subjected by tenants wrongfully holding over
their terms.” (Internal quotation marks omitted.) Bris-
tol v. Ocean State Job Lot Stores of Connecticut, Inc.,
supra, 284 Conn. 5. Because “[s]ummary process statutes
secure a prompt hearing and final determination,” they
6
We certified the following question for review: “Did the Appellate
Court correctly determine that the notice to quit that had been served
on the defendants complied with . . . § 47a-23 because it identified either
the owner of the property or the owner’s attorney, and that the trial
court, therefore, had subject matter jurisdiction over the underlying
summary process action?” Freccia v. Freccia, supra, 352 Conn. 957.
Freccia v. Freccia