• Connecticut Appellate Court
  • Gruendel, J.
Connecticut General Statutes §47a-21(d)(2) allows for landlords to deduct from a tenant's security deposit actual damages, not pretextual damages. The plaintiffs, Luis and Sandra Carrillo, appealed from the trial court's judgment, raising multiple challenges to the award of damages, interest and punitive damages and attorneys' fees under the Connecticut Unfair Trade Practices Act, C.G.S. §42-110a, for the failure of their former landlords, the defendants, Keith and Leigh Ann Goldberg, to return their security deposit in violation of C.G.S. §47a-21(d).
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