Kraiza v. Planning and Zoning Com'n, 304 Conn. 447

Kraiza, Jr. sought subdivision approval for an eight-lot project on 19.57 acres in Hartland near Granby.
Eastwood Drive runs through the adjacent Eastwood subdivision, forming a loop that services ten outside and four inside lots, total length about 3500 feet.
A 50‑foot reserve strip labeled Reserved For Future Road runs from Eastwood Drive to Kraiza’s property.
Hazel Lane would extend 1100 feet from Eastwood Drive to provide access to Kraiza’s eight lots, forming a cul-de-sac; Hazel Lane is not proposed as a through road for Route 20.
The planning commission denied Kraiza’s subdivision application, finding that Hazel Lane plus Eastwood Drive created an extended dead-end street exceeding the 1200‑foot limit.
Both the trial court and Appellate Court treated Eastwood Drive and Hazel Lane as a single continuous dead-end street, applying the 1200‑foot limit to their combined length.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hazel Lane is a continuation of Eastwood Drive for regulatory purposes	Hazel Lane is a separate road, intersecting Eastwood Drive, not a continuation.	Hazel Lane and Eastwood Drive form a single extended dead-end street.	Hazel Lane is not a continuation; they are distinct roads.
Whether Eastwood Drive satisfies the dead-end street definition	Eastwood Drive alone does not constitute a permissible dead-end when Hazel Lane is added.	The combined road length should be considered for the 1200‑foot limit.	Eastwood Drive does not qualify as a dead-end on its own under the regulations.
Whether the 1200‑foot limit and turn-around requirements apply to this subdivision as a whole	Combined length of Hazel Lane and Eastwood Drive exceeds the limit only if treated as one road.	Regulations treat continuous access as a single extended dead-end.	Regulations require treating Hazel Lane and Eastwood Drive as separate roads for the 1200‑foot limit.
How regulations should be interpreted to reconcile dead-end definitions with loop/through designs	Regulations do not contemplate looping roads as dead-ends; strict construction favors Kraiza.	Regulations should be read to allow practical application consistent with access to land.	Regulations must be strictly construed; loop design cannot convert Eastwood into a single dead-end.

Graff v. Zoning Board of Appeals, 277 Conn. 645 (2006) (strict construction of zoning regulations; operative interpretation principles)
Alvord Investment, LLC v. Zoning Board of Appeals, 282 Conn. 393 (2007) (deference to agency determinations; statutory/regulatory interpretation)
Planning & Zoning Commission v. Gilbert, 208 Conn. 696 (1988) (regulatory interpretation and reconciling provisions in zoning)
200 Associates, LLC v. Planning & Zoning Commission, 83 Conn.App. 167 (2004) (loop road/cul-de-sac characterization in regulatory context)
Kraiza v. Planning & Zoning Commission, 121 Conn.App. 478 (2010) (Appellate Court view on dead-end street definitions and Eastwood/Hazel Lane)
Kraiza v. Planning & Zoning Commission, 298 Conn. 904 (2010) (certification/Supreme Court review on proper regulatory interpretation)