Housing Authority v. Cyr, 234 Conn. App. 527 (2025)

Citation: Housing Authority v. Cyr, 234 Conn. App. 527 (2025)
Parent Document: Housing Authority v. Cyr, 234 Conn. App. 527 (2025)
Jurisdiction: Connecticut (state)
Effective Date: 2025-08-26
Original Source: https://www.courtlistener.com/opinion/10659980/housing-authority-v-cyr/ ↗

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In Vidiaki, LLC v. Just Breakfast & Things!!! LLC,
       supra, 133 Conn. App. 1, the defendant claimed that the
       notice to quit had failed to sufficiently apprise it of the
       specific lease violations alleged by the plaintiff. Id., 15.
       The trial court determined that it was ‘‘plausible’’ that
       the defendant did not know all of the purported lease
       violations that the plaintiff would ultimately claim in
       its complaint, and, therefore, the notice to quit was
       invalid. Id., 16. As a result of this conclusion, the trial
       court dismissed the counts of the complaint based on
       the claimed lease violations. Id.
          On appeal, this court reached a contrary conclusion
       on the basis that the notice to quit sufficiently apprised
       the defendant of the alleged lease violations because
       it tracked the statutory language of § 47a-23 (a) and
       (b). Id. Specifically, we noted that the notice to quit
       contained language that informed the defendant to quit
       possession or occupancy for violations of the lease,
       which is one of the bases set forth in the relevant statu-
       tory framework. Id., 18; see General Statutes § 47a-23
       (a) (1) (C). Furthermore, the language in the notice
       to quit regarding violations of the lease tracked the
       language of § 47a-23 (b). Vidiaki, LLC v. Just Break-
       fast & Things!!! LLC, supra, 133 Conn. App. 18. This
       court further concluded: ‘‘Although the notice to quit
       did not lay out specifically the alleged lease violations,
       the notice tracked the statutory language . . . .
       Because the notice to quit adequately met the require-
       ments of § 47a-23, the court improperly dismissed count
       one for lack of subject matter jurisdiction.’’ (Footnote
       omitted.) Id., 19–20.
         The plaintiff’s notice to quit in the present case, like
       the notice to quit in Vidiaki, LLC v. Just Breakfast &
       Things!!! LLC, supra, 133 Conn. App. 1, tracked the
       statutory language and generally informed the defen-
       dant of the reasons for the notice to quit and the termi-
       nation of the lease between the parties. It therefore
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