Headley v. Hartford Housing Authority
A court can find that a letter addressed to "Dear Madam/Sir" of a housing authority does not comply with notice requirements in Connecticut General Statutes §8-67. On Feb. 18, 2010, the plaintiff, Ozzeir Headley, allegedly slipped and fell on ice and snow on the exterior steps of the apartment that he leased. On March 9, 2010, the plaintiff wrote to the Hartford Housing Authority and used the greeting "Dear Madam/Sir," to inform the housing authority about his alleged accident. The plaintiff sued the Hartford Housing Authority and the City of Hartford. The defendants moved to dismiss and argued that the plaintiff failed to comply with notice requirements in C.G.S. §8-67, because he wrote a letter to the Hartford Housing Authority, as opposed to the chairman or the secretary of the Hartford Housing Authority. The deputy executive director of the housing authority, Roy Boling, denied that the housing authority received notice about the plaintiff's intent to sue between Feb. 18 and Aug. 18, 2010. The statute provides, "Any person injured in person or property within boundaries of property owned or controlled by an authority, for which injury such authority is or may be liable, may bring an action within two years after the cause of action therefor arose to recover damages from such authority, provided written notice of the intention to commence such action and of the time when and the place where the damages were incurred or sustained has been filed with the chairman or the secretary of the authority within six months after the cause of action therefor arose." Connecticut courts have strictly construed the language in §8-67. The statute does not include a savings clause. The plaintiff's argument that the statute should be liberally construed lacks merit. There were no genuine issues of material fact about whether the plaintiff followed notice requirements, and the court granted summary judgment to the defendants.