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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. . . Pursuant to § 47a-15, before a landlord may pro-
ceed with a summary process action, except in those
situations specifically excluded, the landlord must first
deliver a [pretermination] notice to the tenant speci-
fying the alleged violations and offer the tenant a . . .
period to remedy. . . . The legislative purpose [of a
pretermination or Kapa14 notice] is to discourage sum-
mary evictions against first offenders . . . . Section
47a-15 is separate from and preliminary to the mainte-
nance of a summary process action pursuant to . . .
[General Statutes] § 47a-23. . . . The Superior Court
has jurisdiction to hear a summary process action only
if the landlord has previously served the tenant with a
notice to quit pursuant to § 47a-23. . . .
‘‘The text of § 47a-15 is clear and unambiguous: Prior
to the commencement of a summary process action
. . . the landlord shall deliver a written notice to the
tenant specifying the acts or omissions constituting the
breach and that the rental agreement shall terminate
upon a date not less than fifteen days after receipt of
the notice. . . . [I]f substantially the same act or omis-
sion for which notice was given recurs within six
months, the landlord may terminate the rental agree-
ment in accordance with the provisions of [§§] 47a-
23 to 47a-23b, inclusive.’’ (Citations omitted; footnote
added; internal quotation marks omitted.) Housing
Authority v. Rodriguez, 178 Conn. App. 120, 126–27,
174 A.3d 844 (2017). ‘‘In order to demonstrate its compli-
ance with the notices required for a proper termination,
a landlord must show that the notices given to the
tenant apprised her of the information a tenant needs
to protect herself against premature, discriminatory or
arbitrary eviction.’’ Jefferson Garden Associates v.
Greene, 202 Conn. 128, 143, 520 A.2d 173 (1987).
In the present case, the defendant maintains that the
plaintiff provided her with an invalid pretermination
14
Kapa Associates v. Flores, 35 Conn. Supp. 274, 278, 408 A.2d 22 (1979).
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