hartford/windsor Healthcare Properties, LLC v. City of Hartford; Trinity Hill Realty, LLC v. City of Hartford

Summary

The court affirmed the classification of the plaintiffs’ nursing homes as commercial rather than apartment property under the Hartford property-tax system. It held that the statutory phrase “dwelling units used for human habitation” is ambiguous, but that the statutory text, related statutes, and legislative purpose demonstrate that nursing homes do not qualify as apartment property. The court reasoned that the statute was designed to moderate taxes on owner-occupied residential and apartment property, a purpose not advanced by extending the benefit to nursing homes.