§ 966

Citation: § 966
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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Greene, supra, 202 Conn. 128, and Housing Authority
v. Curtis, Superior Court, judicial district of Danbury,
Docket No. SP-05-12308 (March 27, 2006) (41 Conn. L.
Rptr. 129) (court concluded that tenant’s claim that
landlord failed to include specific language from federal
regulation constituted hypertechnical attack that
exalted form over substance and determined that notice
complied with said regulation despite minor deviation).
Our Supreme Court has emphasized that, with regard
to both state and federal law, a landlord, in demonstra-
ting its compliance with the notices required to proceed
with a summary process action, must show that the
notices apprised the tenant of the information needed to
protect against premature, discriminatory, or arbitrary
eviction. Jefferson Garden Associates v. Greene, supra,
202 Conn. 143 (citing Joy v. Daniels, 479 F.2d 1236,
1241 (4th Cir. 1973), and Anderson v. Denny, 365 F.
Supp. 1254, 1260 (W.D. Va. 1973)). Ritualistic compli-
ance with statutory or regulatory mandates is not
required. Jefferson Garden Associates v. Greene, supra,
144. It further explained: ‘‘For such tenants [of federally
subsidized housing], despite a recognition that a loss
of federally subsidized housing implicates due process
rights under the fifth amendment to the United States
constitution, federal law has moved away from requir-
ing either a special federal forum or special federal
forms. Federal courts have concluded that a tenant’s
right to fair adjudication of good cause for the termina-
tion of his tenancy can be vindicated by recourse to
the normal judicial process of state court eviction pro-
cedures.’’ Id.
Given this development, our Supreme Court con-
cluded that judicial evaluation of compliance with both
federal and state requirements for notices regarding the
termination of a lease must reflect the purpose that
these notices were meant to serve. Id., 145. ‘‘As we
have held in other contexts, in which regulatory and
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