Northland Investment Corp. v. Public Utilities Regulatory Authority

Summary

The court held that Connecticut law prohibits a landlord from using ratio utility billing to charge tenants estimated shares of building-wide utility costs when the building has only a master meter. The court construed the governing statute broadly in light of its remedial purpose, concluding that tenants may not be held liable to anyone for utility costs they did not exclusively use. It distinguished the permissible practice of incorporating estimated utility costs into fixed rent from RUB because the former provides predictable payments and places the risk of underestimation on the landlord.