Conn. Gen. Stat. » Title 47a — LANDLORD AND TENANT · Chapter 830 — Rights and Responsibilities of Landlord and Tenant
Connecticut General Statutes

Conn. Gen. Stat. § 47a-3c (2026)

Payment in absence of rental agreement

✓ current as of May 2026
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In the absence of agreement, the tenant shall pay the fair rental value for the use and occupancy of the dwelling unit.

(P.A. 79-571, S. 7.)

Cited. 4 CA 608; 13 CA 150; 16 CA 574; 17 CA 92. Illegal lease contrasted with situation contemplated by statute where recovery for use and occupancy is premised on absence of lease or termination of valid lease agreement by notice to quit. 24 CA 385. Cited. 27 CA 706.

Cited. 38 CS 683.

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Notes of Decisions
Cited in 14 cases (2 in the last 5 years), 1983–2024 · leading case: City of Bridgeport v. Barbour-Daniel Elec., Inc., 548 A.2d 744 (Conn. App. Ct. 1988).
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City of Bridgeport v. Barbour-Daniel Elec., Inc., 548 A.2d 744 (Conn. App. Ct. 1988). · cites it 14× “” Although we need not address this issue, we note that had we been confronted with deciding the issue, we would have concluded, as does the dissent, that the nonpayment of use and occupancy is not a proper ground for eviction and, therefore, cannot sustain a summary process…”
Brewster Park, LLC v. Berger, 14 A.3d 334 (Conn. App. Ct. 2011). · cites it 16× “The defendant correctly asserts that there was no reference in the complaint to General Statutes § 47a-3c, [6] which provides for the remedy of use and occupancy payments.”
300 State, LLC v. Hanafin, 59 A.3d 287 (Conn. App. Ct. 2013). · cites it 11× “The defendant interprets the court’s use of the phrase “for the occupancy of the leased premises” to mean “use and occupancy” in the context of General Statutes § 47a-3c. 3 Section 47a-3c provides: “In the absence of agreement, the tenant shall pay the fair rental value for the…”
City of New Haven v. Mason, 550 A.2d 18 (Conn. App. Ct. 1988). · cites it 7× “First, the plaintiffs complaint makes no reference to General Statutes § 47a-3c. The term “use and occupancy” is a term of art that has been embodied in General Statutes § 47a-3c, providing the remedy of use and occupancy payments absent a rental agreement.”
Bushnell Plaza Dev. Corp. v. Fazzano, 460 A.2d 1311 (Conn. Super. Ct. 1983). · cites it 5× “The trial court’s conclusion that past practices of rental payment constituted a fair barometer of reasonable use and occupancy, although not incorrect, misspeaks the issue.”
Leblanc v. Tri-town Shelton Servs., Inc., 955 A.2d 55 (Conn. App. Ct. 2008). · cites it 8× “It awarded the plaintiff $8400 in back rent under the holdover provisions of the lease or, alternatively, for the fair rental value for use and occupancy pursuant to General Statutes § 47a-3c. 2 As to the second count, the court was unable to ascertain the extent to which the…”
Hous. Auth. of East Hartford v. Hird, 535 A.2d 377 (Conn. App. Ct. 1988). · cites it 2× “When the defendant requested reinstatement as a tenant during the pendency of the second eviction action, the plaintiff replied through its attorney on January 7,1986, that “the Housing Authority does not wish to have Ms.”
Sippin v. Ellam, 588 A.2d 660 (Conn. App. Ct. 1991). · cites it 4× “*391 The plaintiff finally suggests in his brief that, because General Statutes § 47a-3c provides for recovery of payments for use and occupancy, he is entitled to the same under the facts of this case.”
Rivera v. Santiago, 495 A.2d 1122 (Conn. App. Ct. 1985). · cites it 2× “Use of that phrase in the statute indicates that a tenancy at sufferance falls within the court’s jurisdiction pursuant to the statute.”
Boardwalk Realty Assocs., LLC v. M & S Gateway Assocs., LLC, 340 Conn. 115 (Conn. 2021). “3d 740 (2019) (summary process was not exclusive remedy, and property owner could seek use and occupancy via unjust enrichment action); see also Gen- eral Statutes § 47a-3c (‘‘[i]n the absence of agreement, the tenant shall pay the fair rental value for the use and occupancy of…”
Edgewood Props., LLC v. Dynamic Multimedia, LLC, 226 Conn. App. 583 (Conn. App. Ct. 2024). “)); see also General Statutes § 47a-3c (‘‘[i]n the absence of agreement, the tenant shall pay the fair rental value for the use and occupancy of the dwelling unit’’); General Statutes § 47a-26b (pro- viding for use and occupancy payments to be made, upon motion, during pendency…”
Gionfriddo v. Carter-Howe Dev. Corp., 609 A.2d 662 (Conn. App. Ct. 1992). · cites it 2× “Finally, the plaintiff claims that the trial court abused its discretion in allowing the defendant to amend its counterclaim during the trial to include a claim for use and occupancy.”
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