Housing Authority v. Harris

611 A.2d 934, 28 Conn. App. 684, 1992 Conn. App. LEXIS 327
CourtConnecticut Appellate Court
DecidedAugust 18, 1992
Docket10802
StatusPublished
Cited by11 cases

This text of 611 A.2d 934 (Housing Authority v. Harris) is published on Counsel Stack Legal Research, covering Connecticut Appellate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Housing Authority v. Harris, 611 A.2d 934, 28 Conn. App. 684, 1992 Conn. App. LEXIS 327 (Colo. Ct. App. 1992).

Opinion

Landau, J.

The defendant Mary Harris1 appeals from the trial court judgment of possession in favor of the plaintiff, the housing authority of the city of Norwalk (housing authority), in a summary process action. The dispositive issue in this appeal, a question of first impression in this state, is whether the plaintiff was required to include a “Kapa notice”2 in its notice to quit as a condition precedent to commencing the summary process action against the defendant.3 We con-[686]*686elude that a Kapa notice was required in the plaintiffs notice to quit in order to confer jurisdiction on the trial court.

The following undisputed facts are relevant to our resolution of this appeal. The defendant, a widowed mother of seven, has been living in Roodner Court, federally subsidized public housing, in Norwalk since 1959. In September of 1983, the plaintiff and the defendant entered into a written lease of apartment 3F in building twenty-three of Roodner Court. Also living in the apartment and specifically named on the lease are the defendant’s children, Mary Harris, Jr., and Parks Harris, Jr. On March 1,1990, Mary, Jr., was arrested for selling narcotics in an outdoor stairwell between buildings eleven and twelve at Roodner Court, an area that could not be seen from the defendant’s apartment. The police connected neither the defendant nor her apartment with the daughter’s illegal conduct. As a direct result of the daughter’s arrest, the plaintiff caused a notice to quit possession to be served on the defendant on June 1,1990.4 The notice to quit alleged that the defendant had failed to meet her duty as a tenant under General Statutes § 47a-ll (g)5 6to require others on the premises with her consent to conduct themselves in a manner that does not constitute a serious nuisance. Specifically, the notice to quit alleged that she created a serious nuisance by using or permitting the use of the premises for illegal sale of drugs. The notice did not inform the defendant of her statutorily [687]*687guaranteed right to rectify the alleged violation within twenty-one days. General Statutes § 47a-15.6 The defendant remained in possession and the plaintiff instituted a summary process action seeking a judgment of possession against the defendant. The plaintiffs complaint in the summary process action alleged that Mary Harris, Jr., “committed acts upon the premises which constituted use of the premises for the illegal sale of drugs” and that “[her] conduct . . . on the premises constitutes a serious nuisance as defined in [General Statutes] § 47a-15, in violation of [General Statutes] § 47a-ll (g).” There is no reference to any conduct on the part of the defendant. In her fourth special defense, the defendant alleged that the plaintiff failed to notify her as required by § 47a-15.

The trial court concluded, inter alia, that the defendant “failed to require Mary, Jr., to conduct herself in a manner that did not constitute a serious nuisance” and that “a Kapa notice ... is not required where a tenant has caused a serious nuisance.” On the basis of these findings, the trial court rendered judgment for the plaintiff. From this judgment, the defendant has appealed.

The defendant argues that the plaintiff was required, pursuant to General Statutes § 47a-15, to notify the defendant in writing prior to the commencement of the [688]*688summary process action of the particular acts or omissions forming the basis of the términation and the fact that she was entitled to twenty-one days to rectify the misuse. The essence of the defendant’s argument is that § 47a-15 requires landlords to notify tenants of these rights except where specifically exempted in that statute, and that her conduct does not fall within one of the enumerated exemptions. Specifically, as related to this case, the defendant argues that General Statutes § 47a-15 exempts the plaintiff from providing such notification only where the landlord elects “to evict based on . . . conduct by the tenant which constitutes a serious nuisance”; (emphasis added); General Statutes § 47a-15; and that because the plaintiff neither alleged nor proved any conduct of the defendant that would constitute a serious nuisance, the plaintiff was required to adhere to the notice requirement of General Statutes § 47a-15. The plaintiff argues that the language of § 47a-15, that exempts the plaintiff from adhering to its notice requirement based on “conduct by the tenant which creates a serious nuisance,” necessarily includes the defendant, as well as her daughter,7 because the purpose of the statute is to hold tenants liable for the activities of all members of the household. We agree with the defendant.

Summary process is a statutory remedy that enables a landlord to recover possession from a tenant on the termination of alease. General Statutes § 47a-23. The remedy of summary process is available only when there is a lease and the lease has been terminated. Jefferson Garden Associates v. Greene, 202 Conn. 128, 143, 520 A.2d 173 (1987). “ ‘Because of the summary nature of this remedy, the statute granting it has been [689]*689narrowly construed and strictly followed.’ ” Jo-Mark Sand & Gravel Co. v. Pantanella, 139 Conn. 598, 600-601, 96 A.2d 217 (1953); Marrinan v. Hamer, 5 Conn. App. 101, 103, 497 A.2d 67 (1985). It follows that, before a landlord may pursue its statutory remedy of summary process, the landlord must prove compliance with all of the applicable preconditions set by state and federal law for the termination of a lease. “[Summary process] is preceded by giving the statutorily required notice to quit possession to the tenant. Webb v. Ambler, 125 Conn. 543, 552-53, 7 A.2d 228 (1939).” Housing Authority v. Hird, 13 Conn. App. 150, 155, 535 A.2d 377, cert. denied, 209 Conn. 825, 552 A.2d 433 (1988); Marrinan v. Hamer, supra. “As a condition precedent to a summary process action, proper notice to quit is a jurisdictional necessity.” Lampasona v. Jacobs, 209 Conn. 724, 729, 553 A.2d 175, cert. denied, 492 U.S. 919, 109 S. Ct. 3244, 106 L. Ed. 2d 590 (1989); Ossen v. Kreutzer, 19 Conn. App. 564, 568, 563 A.2d 741 (1989). “In order to demonstrate its compliance 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. ... To further this salutary purpose, the notice requirements of § 47a-15 must be construed strictly.” (Citations omitted.) Jefferson Garden Associates v. Greene, supra, 143-44.

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Bluebook (online)
611 A.2d 934, 28 Conn. App. 684, 1992 Conn. App. LEXIS 327, Counsel Stack Legal Research, https://law.counselstack.com/opinion/housing-authority-v-harris-connappct-1992.