The Connecticut Appellate Court recently ruled in favor of Shauna Giuliano, a tenant, in a case against her landlord, Sarjac Partners, LLC. The court's decision, released on June 30, 2026, affirms the trial court's judgment that the landlord had breached their lease agreement and constructively evicted the tenant. This ruling is significant as it underscores the responsibilities landlords have in maintaining rental properties.
The case began when Sarjac Partners, LLC, which manages a commercial property in West Hartford, claimed that Giuliano had breached her lease by vacating the premises early. However, Giuliano countered with claims of constructive eviction, alleging that Sarjac Partners had failed to maintain the property adequately, making it unfit for her business operations.
Background
Sarjac Partners, LLC is a property management company that oversees a multiunit commercial building located at 36 LaSalle Road in West Hartford. In July 2022, they entered into a four-year lease agreement with Shauna Giuliano, who operated a hair salon in one of the units. The lease was effective from September 1, 2021, to August 31, 2025.
According to the lease, Sarjac Partners was responsible for keeping the premises reasonably maintained, provided Giuliano was not in default on her rent obligations. However, in August 2023, Giuliano did not pay her rent and subsequently vacated the premises. In February 2024, Sarjac Partners filed a lawsuit against Giuliano, claiming she had breached the lease by leaving early. Giuliano responded with a counterclaim, asserting that she had been constructively evicted due to the landlord's failure to maintain the property.
The Ruling
The Connecticut Appellate Court, consisting of Chief Judge Cradle and Judges Elgo and Westbrook, reviewed the case and upheld the trial court's decision. The court found that the trial court's findings were not clearly erroneous and supported by evidence. The judges noted, "We cannot conclude that the findings were not supported by any evidence, nor were we left with the definite and firm conviction that a mistake had been made."
The trial court had determined that Sarjac Partners failed to maintain the property adequately, which led to conditions that were detrimental to Giuliano's business. The court highlighted that the premises had serious maintenance issues, including unsanitary common areas and malfunctioning elevators. Giuliano testified that these issues negatively impacted her business and led her to vacate the premises.
Impact
This ruling has important implications for landlords and tenants in Connecticut. It reinforces the legal obligation of landlords to maintain their properties in a condition that is suitable for tenants' intended use. The court's decision emphasizes that failure to do so can lead to claims of constructive eviction, allowing tenants to leave without penalty if the property becomes untenantable.
The case also highlights the importance of communication between landlords and tenants regarding maintenance issues. The court found that Giuliano had repeatedly notified Sarjac Partners about the problems but that the landlord failed to take adequate action. This ruling may encourage tenants to be more proactive in documenting maintenance issues and communicating with their landlords.
What's Next
The court's decision can be appealed, but it is unclear if Sarjac Partners intends to pursue further legal action. There are no related cases pending that were mentioned in the court filing. For now, this ruling stands as a precedent for similar disputes involving constructive eviction and landlord responsibilities in Connecticut.