Conn. Gen. Stat. » Title 47a — LANDLORD AND TENANT · Chapter 833a — Public Enforcement of Health and Safety Standards in Tenement and Boarding Houses, and in Rented Dwellings
Connecticut General Statutes

Conn. Gen. Stat. § 47a-57 (2026)

(Formerly Sec. 19-347r). Certificate of occupancy required for lawful occupation. Penalty for allowing occupancy without certificate

✓ current as of May 2026
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(a) An apartment or dwelling unit in any structure containing three or more housing units in any municipality which adopts the provisions of this section by vote of its legislative body shall not be occupied for human habitation, after a vacancy, until a certificate of occupancy has been issued by the person designated by the legislative body of such municipality to administer the provisions of this section, certifying that such apartment or dwelling unit conforms to the requirements of the applicable housing ordinances of such municipality and this chapter. No provision of this section shall apply to any structure occupied by the owner thereof and containing three or less housing units. No provision of this section shall be construed to prohibit human occupancy of such apartment or dwelling unit during the pendency of an application for such certificate.

(b) Any person aggrieved by the refusal of a certificate of occupancy may appeal to the superior court for the judicial district within which the structure is located. Such appeal shall be privileged.

(c) Any owner or lessor who recovers rent for the occupation of any apartment or dwelling unit for which a certificate of occupancy has not been obtained prior to the rental thereof in violation of subsection (a) of this section shall be liable for a civil penalty of not more than twenty dollars per day for not more than two hundred days for such period of unlawful occupation.

(d) The provisions of this section shall not apply to any structure which has been constructed or substantially reconstructed within the ten-year period immediately before the date such certificate of occupancy would otherwise be required under this section.

(1969, P.A. 462, S. 1–3; 1971, P.A. 413, S. 1; 570; P.A. 76-436, S. 390, 681; P.A. 77-495; P.A. 78-280, S. 1, 127; P.A. 79-571, S. 93; P.A. 84-80; P.A. 93-260; May Sp. Sess. P.A. 94-1, S. 41, 130; P.A. 97-231, S. 5; P.A. 98-107, S. 5, 6.)

History: 1971 acts excluded from applicability of section apartment houses owned by housing authorities, constructed or altered pursuant to state or federal contract in Subsec. (c), applied Subsec. (a) to apartment houses of four or more rather than six or more units and excluded from applicability of section apartment houses constructed or reconstructed within 15 years next “preceding” rather than “succeeding” the date a certificate of occupancy would be required; P.A. 76-436 replaced court of common pleas with superior court and added reference to judicial districts in Subsec. (a), effective July 1, 1978; P.A. 77-495 replaced “apartment house” with “structure” where appearing, changed applicable number of housing units to three in Subsec. (a), adding proviso re owner-occupied structure having three or less units, and in Subsec. (c) changed applicable period re construction or reconstruction from 15 to 10 years preceding date certificate of occupancy would be required; P.A. 78-280 deleted reference to counties in Subsec. (a); P.A. 79-571 rephrased provisions and reorganized subsections; Sec. 19-347r transferred to Sec. 47a-57 in 1981; P.A. 84-80 removed exemption in Subsec. (d) for housing authority apartment houses; P.A. 93-260 amended Subsec. (c) to add provisions requiring any rent received in violation of this section to be deposited in an escrow account, requiring the owner or lessor to maintain the account as escrow agent and prohibiting the withdrawal of such rent until a certificate of occupancy is issued; May 25 Sp. Sess. P.A. 94-1 amended Subsec. (a) by making technical change, effective July 1, 1994; P.A. 97-231 amended Subsec. (c) to replace provisions prohibiting the recovery of rent during any period that an apartment or dwelling unit is occupied without a certificate of occupancy and requiring any rent received in violation of Subsec. (a) to be deposited in an escrow account with provision establishing a civil penalty of $20 per day for any period that an owner or lessor recovers rent for the occupation of an apartment or dwelling unit without having obtained a certificate of occupancy; P.A. 98-107 amended Subsec. (c) to limit the liability of the owner or lessor for the daily civil penalty to a period of not more than 200 days, effective July 1, 1998.

See Sec. 19a-362 prohibiting recovery of rent during unlawful occupation.

See Sec. 29-265 re issuance of certificate of occupancy.

Cited. 191 C. 484.

Cited. 10 CA 527; 17 CA 421.

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Notes of Decisions
Cited in 6 cases, 1983–2011 · leading case: Conaway v. Prestia, 464 A.2d 847 (Conn. 1983).
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Conaway v. Prestia, 464 A.2d 847 (Conn. 1983). · cites it 7× “Subsection (a) of § 47a-57 unequivocally states that “housing units .”
Greater New Haven Prop. Owners Ass'n v. City of New Haven, 951 A.2d 551 (Conn. 2008). · cites it 20× “Specifically, § 47a-57, if adopted by a municipality, requires that, following a vacancy, a certificate of occupancy, certifying that the rental unit “conforms to the requirements of the applicable housing ordinances of such municipality and this chapter” be issued for an…”
A & M Towing & Recovery, Inc. v. Guay, 923 A.2d 628 (Conn. 2007). · cites it 7× “if landlord fails to provide essential services that it is required to provide); General Statutes § 47a-52 (c) (authorizing department of health to bring civil action to abate “danger to life or health” from defect in plumbing, sewerage, water supply, drainage, lighting,…”
Hernandez v. Monterey Vill. Assocs. Ltd. P'ship, 553 A.2d 617 (Conn. App. Ct. 1989). · cites it 2× “The plaintiffs also alleged that the dwelling units occupied by the class members were in a condition violating state and local housing laws and ordinances, that no certificates of apartment occupancy had been issued on the dwellings as required by city ordinance, and that the…”
Szekeres v. Szekeres, 16 A.3d 713 (Conn. App. Ct. 2011). · cites it 2× “In Conaway , our Supreme Court held that the defendants’ conduct constituted unfair or deceptive acts in violation of CUTPA in that the defendants clearly had the responsibility for obtaining certificates of occupancy, and their collection of rent without those certificates…”
Tillquist v. Ford Motor Credit Co., 714 F. Supp. 607 (D. Conn. 1989). “Plaintiff has proven that defendant has violated several of the banking regulations; therefore, the Court concludes that defendant’s actions amount to a breach of public policy and in turn violate the CUTPA. *617 D. Damages Since plaintiff has sustained his burden of proof with…”
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.