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Jefferson Garden Associates v. Greene

Citations: 202 Conn. 128; 520 A.2d 173; 1987 Conn. LEXIS 736Docket: 12572

Court: Supreme Court of Connecticut; January 27, 1987; Connecticut; State Supreme Court

Narrative Opinion Summary

This case examines the termination of a residential lease for non-compliance with a no pets clause, under the auspices of both state and federal housing regulations. The plaintiff, a landlord of a low-income housing project, initiated eviction proceedings against the tenant for keeping a dog without written permission, contravening a lease provision. The trial court found in favor of the landlord, confirming that the lease's prohibition on pets was enforceable and that the landlord had fulfilled all statutory and regulatory notice requirements. The tenant contested the adequacy and timing of the termination notices, arguing they failed to comply with both state law and federal regulations applicable to subsidized housing. However, the court upheld the notices' validity, determining they adequately informed the tenant of the termination date and her rights. Additionally, the court confirmed the admissibility of the termination notices as business records under state law. Ultimately, the landlord's compliance with procedural requirements for lease termination and eviction was affirmed, resulting in the tenant's eviction due to the ongoing violation of the no pets clause.

Legal Issues Addressed

Admissibility of Business Records Under General Statutes 52-180

Application: The court admitted the termination notices as business records, finding them trustworthy and prepared in the usual course of business by the plaintiff's property manager.

Reasoning: The court concluded that this testimony satisfied the requirements under General Statutes 52-180.

Burden of Proof in Lease Termination Proceedings

Application: The court determined that the landlord met the burden of proof in showing compliance with statutory notice requirements, rejecting the defendant's claim of improper notice delivery.

Reasoning: The plaintiff provided testimony that the notice was mailed and personally served on the same day.

Eviction Procedures in Section 8 Housing

Application: The court held that federal regulations defer to state law for notice content, emphasizing the importance of tenant rights protection in eviction proceedings.

Reasoning: Federal courts have determined that tenants can seek fair adjudication through state court eviction processes.

Notice Requirements in Federally Subsidized Housing

Application: The court found that the plaintiff's notices complied with federal regulations governing subsidized housing, ensuring proper notice was given under 24 C.F.R. 450.

Reasoning: The relevant regulation, 24 C.F.R. 450.4(a), requires the written notice to inform the tenant of the termination date, reasons for termination, and the tenant's right to defend against eviction.

Termination of Lease Under General Statutes 47a-15

Application: The court upheld the landlord's termination of the tenant's lease due to a violation of the no pets clause, which was clearly stipulated in the lease agreement.

Reasoning: The trial court ruled in favor of the plaintiff, maintaining the binding nature of the no pets clause and rejecting Greene's security concerns as justification for her violation.