Connecticut General Statutes

Conn. Gen. Stat. § 47a-20a (2026)

Actions deemed not retaliatory

✓ current as of May 2026
Find cases: SyfertCases citing this section CT-CGAcga.ct.gov (official) JustiaTitle on Justia CornellLII Search CasesGoogle Scholar
(a) Notwithstanding the provisions of section 47a-20, the landlord may maintain an action to recover possession of the dwelling unit if: (1) The tenant is using the dwelling unit for an illegal purpose or for a purpose which is in violation of the rental agreement or for nonpayment of rent; (2) the landlord seeks in good faith to recover possession of the dwelling unit for immediate use as his own abode; (3) the condition complained of was caused by the wilful actions of the tenant or another person in his household or a person on the premises with his consent; or (4) the landlord seeks to recover possession on the basis of a notice to terminate a periodic tenancy, which notice was given to the tenant before the tenant's complaint.

(b) Notwithstanding the provisions of section 47a-20, a landlord may increase the rent of a tenant if: (1) The condition complained of was caused by the lack of due care by the tenant or another person of his household or a person on the premises with his consent or (2) the landlord has become liable for a substantial increase in property taxes, or a substantial increase in other maintenance or operating costs not associated with his complying with the complaint, not less than four months before the demand for an increase in rent, and the increase in rent does not exceed the prorated portion of the net increase in taxes or costs.

(c) Nothing in this section or section 47a-20 shall be construed to in any way limit the defense provided in section 47a-33.

(P.A. 79-571, S. 18.)

See Sec. 47a-33 re defense that action is retaliatory.

Cited. 217 C. 313.

Cited. 4 CA 128; 16 CA 444; 32 CA 133. Section contains four exclusive grounds by which a landlord may rebut a presumption of retaliation under Sec. 47a-20 and because landlord did not prove at least one of those four grounds, he did not rebut the presumption of retaliation under Sec. 47a-20. 91 CA 142.

Cited. 38 CS 683; 40 CS 470.

Secs. 47a-20b to 47a-20d. Reserved for future use.

Notes of Decisions
Cited in 10 cases (3 in the last 5 years), 1985–2026 · leading case: Correa v. Ward, 881 A.2d 393 (Conn. App. Ct. 2005).
Correa v. Ward, 881 A.2d 393 (Conn. App. Ct. 2005). · cites it 23× “On appeal, the defendant claims that the plaintiffs proffered rebuttal did not satisfy any of the grounds listed in General Statutes § 47a-20a 3 and that the court improperly interpreted those grounds not to be exclusive.”
Wilson v. Jefferson, 908 A.2d 13 (Conn. App. Ct. 2006). · cites it 6× “5 General Statutes § 47a-20a enumerates four bases by which a landlord may overcome the presumption of retaliatory eviction.”
Renaissance Mgmt. Co. v. Barnes, 168 A.3d 530 (Conn. App. Ct. 2017). · cites it 5× “1 The court granted the defendant's motion for summary judgment on the ground that the plaintiff was prohibited by the retaliatory eviction statute; General Statutes § 47a-20 ; from initiating the action and that the exceptions claimed by the plaintiff under General Statutes §…”
Holdmeyer v. Thomas, 144 A.3d 1052 (Conn. App. Ct. 2016). · cites it 10× “The defendant claims that the plaintiff did not meet his burden of rebutting the presumption of retaliatory eviction because he did not prove any of the four statutory exceptions enumerated in General Statutes § 47a-20a. 1 We agree and reverse the judgment of the trial court.”
Visco v. Cody, 547 A.2d 935 (Conn. App. Ct. 1988). · cites it 2× “(a) Notwithstanding the provisions of section 47a-20, the landlord may maintain an action to recover possession of the dwelling unit if: (1) The tenant is using the dwelling unit for an illegal purpose or for a purpose which is in violation of the rental agreement or for…”
Mobilia, Inc. v. Santos, 492 A.2d 544 (Conn. App. Ct. 1985). · cites it 2× “General Statutes § 47a-20a. The second special defense requested equitable relief against forfeiture on the basis of hardship and the forced sale of their mobile home.”
Murphy v. Baez, 515 A.2d 383 (Conn. Super. Ct. 1986). · cites it 8× “” The defendant also contends that the presumption may not be rebutted by reasons other than those set forth in § 47a-20a and that the plaintiff has failed to prove that any of those provisions apply in the present case.”
Kosel Equity, LLC v. MacGregor (Conn. 2026). · cites it 12× “7 See General Statutes § 47a-20a (a); see also Correa v.”
TOV Realty, LLC v. Suarez (Conn. 2026). · cites it 7× “General Statutes § 47a-20a, however, provides exceptions to § 47a-20 and permits a “landlord [to] maintain an action to recover possession of the dwelling unit” for, among other reasons, “[t]he tenant .”
Maye v. Strollo (D. Conn. 2023). “§ 47a-20a(a) (landlord may maintain action to recover premises if certain conditions are met.”
— Conn. Gen. Stat. § 47a-20a(2) — 1 case
Wilson v. Jefferson, 908 A.2d 13 (Conn. App. Ct. 2006). “5 General Statutes § 47a-20a enumerates four bases by which a landlord may overcome the presumption of retaliatory eviction.”
— Conn. Gen. Stat. § 47a-20a(a) — 1 case
Maye v. Strollo (D. Conn. 2023). “§ 47a-20a(a) (landlord may maintain action to recover premises if certain conditions are met.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.