This section contains the nature of the case and procedural background.

On July 11, 2014, D called the Uncas Health District to complain that the apartment he rented from P had been infested with bed bugs. An inspection confirmed that it had been infested, and an order of violation was issued on July 18. P testified that he did not receive the order until July 30, 2014. On August 29, 2014, P commenced a summary process action against D, seeking to remove D from P's property. The complaint alleged that the week-to-week tenancy had terminated by lapse of time, and P attached a copy of the notice to quit, dated August 15, 2014. The court determined that the evidence submitted by D supported the finding of a presumption of retaliation under General Statutes § 47a-20. The court held that P successfully rebutted this presumption by showing that the eviction was not in fact retaliatory. The court rendered a judgment of possession in favor of P. On a motion to open and reargue, the court again found that P had rebutted the presumption of a retaliatory eviction. The court rendered a judgment of immediate possession in favor of P. D appealed. D argues that the only means available to rebut a presumptively retaliatory eviction, pursuant to § 47a-20, are the four specific exceptions enumerated in § 47a-20a, none of which the court found in this case.

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