Section 21-80a

Citation: Section 21-80a
Parent Document: Fairchild Heights, Inc. v. Dickal, 45 A.3d 627 (2012)
Jurisdiction: Connecticut (state)
Effective Date: 2012-06-26
Original Source: https://www.courtlistener.com/opinion/2295282/fairchild-heights-inc-v-dickal/ ↗

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Two important textual clues further illuminate the meaning of the pertinent exception. *644 The conduct at issue is linked in the conjunctive with two other acts, namely, "using the dwelling unit or the premises for an illegal purpose ... or for nonpayment of rent...." General Statutes § 21-80a (b)(1). This linkage suggests that the legislature intended each of the three categories to describe similarly egregious conduct. "Where a provision contains two or more words grouped together, we often examine a particular word's relationship to the associated words and phrases to determine its meaning pursuant to the canon of construction noscitur a sociis." (Internal quotation marks omitted.) McCoy v. Commissioner of Public Safety, 300 Conn. 144, 159, 12 A.3d 948 (2011). This view is bolstered by the legislature's use of the term "purpose" in two of the three acts described. Because using the dwelling unit or the premises for an illegal purpose and failing to pay rent are both patent violations of fundamental tenant obligations, the third category  use "for a purpose which is in violation of the rental agreement"  reasonably must construed to refer to a comparably fundamental violation.

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