Milford Redevelopment & Housing Partnership v. Glicklin, 228 Conn. App. 593 (2024)

Citation: Milford Redevelopment & Housing Partnership v. Glicklin, 228 Conn. App. 593 (2024)
Parent Document: Milford Redevelopment & Housing Partnership v. Glicklin, 228 Conn. App. 593 (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-10-15
Original Source: https://www.courtlistener.com/opinion/10136084/milford-redevelopment-housing-... ↗

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notice it provided to the defendant contained ‘‘sufficient
information to enable [her] to remedy or cure the viola-
tion . . . .’’ We agree with the plaintiff.
Although the defendant raises this argument for the
first time in her appellate brief, we nevertheless address
it on appeal. See Mention v. Kensington Square Apart-
ments, supra, 214 Conn. App. 727 (claim that court
lacks subject matter jurisdiction can be raised at any
time during proceedings, including on appeal). The fol-
lowing legal principles are, thus, necessary for our reso-
lution of this claim. With respect to federal law, ‘‘[s]er-
vice of a valid pretermination notice is a condition
precedent to a summary process action. See [24 C.F.R.]
§ 247.4 [2018].13 In any subsequent summary process
action, the landlord can rely only on grounds that were
set forth in that notice, unless the landlord had no
knowledge of an additional ground at the time the pre-
termination notice was served. . . . With respect to
the statement of such grounds in the pretermination
notice, the regulations mandate that the notice must,
among other things, state the reasons for the landlord’s
action with enough specificity so as to enable the tenant
to prepare a defense . . . .’’ (Citation omitted; emphasis
in original; footnote altered; internal quotation marks
omitted.) Presidential Village, LLC v. Perkins, supra,
332 Conn. 57.
In Connecticut, ‘‘[s]ummary process is a statutory
remedy which enables the landlord to recover posses-
sion from the tenant upon the termination of a lease.
13
‘‘Title 24 of the 2018 edition of the Code of Federal Regulations, § 247.4
(a), provides: ‘The landlord’s determination to terminate the tenancy shall
be in writing and shall: (1) State that the tenancy is terminated on a date
specified therein; (2) state the reasons for the landlord’s action with enough
specificity so as to enable the tenant to prepare a defense; (3) advise the
tenant that if he or she remains in the leased unit on the date specified for
termination, the landlord may seek to enforce the termination only by bring-
ing a judicial action, at which time the tenant may present a defense; and
(4) be served on the tenant in the manner prescribed by paragraph (b) of
this section.’ ’’ Presidential Village, LLC v. Perkins, supra, 332 Conn. 57 n.12.
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