Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich

************************************************
The “officially released” date that appears near the
beginning of an opinion is the date the opinion will be
published in the Connecticut Law Journal or the date it
is released as a slip opinion. The operative date for the
beginning of all time periods for the filing of postopinion
motions and petitions for certification is the “officially
released” date appearing in the opinion.
All opinions are subject to modification and technical
correction prior to official publication in the Connecti-
cut Law Journal and subsequently in the Connecticut
Reports or Connecticut Appellate Reports. In the event
of discrepancies between the advance release version of
an opinion and the version appearing in the Connecticut
Law Journal and subsequently in the Connecticut Reports
or Connecticut Appellate Reports, the latest version is
to be considered authoritative.
The syllabus and procedural history accompanying an
opinion that appear in the Connecticut Law Journal and
subsequently in the Connecticut Reports or Connecticut
Appellate Reports are copyrighted by the Secretary of the
State, State of Connecticut, and may not be reproduced
or distributed without the express written permission of
the Commission on Official Legal Publications, Judicial
Branch, State of Connecticut.
************************************************

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
THE LEE MEMORIAL METHODIST CHURCH OF
NORWICH, CONNECTICUT v. CITY
OF NORWICH
(AC 47726)
Westbrook, Wilson and DiPentima, Js.
Syllabus
The defendant town appealed from the trial court’s judgment sustaining
the plaintiff church’s appeal from the defendant’s denial of a tax exemption
pursuant to statute (§ 12-81 (14)) for a portion of the plaintiff’s real property
leased to a for-profit, licensed daycare facility. The defendant claimed, inter
alia, that the court misapplied the plain language of § 12-81 (14). Held:
The defendant’s claim that the trial court misapplied the plain language of
§ 12-81 (14) because the plaintiff’s property was not used exclusively as a
daycare facility was unavailing, as the statutory language does not require
that the plaintiff be affiliated with or operate the daycare facility on its
property in order for the tax exemption to apply.
The trial court properly reconciled the statutory requirements of § 12-81
(14) with the tax exemption statute (§ 12-88) governing its provisions, as the
property leased by the daycare facility was owned by the plaintiff, a religious
organization, used exclusively as a daycare facility, and leased in furtherance
of the purpose intended under § 12-81 (14), namely, as a daycare facility.
The defendant’s claim that the trial court erred in failing to apply the prin-
ciple of noscitur a sociis to supply the phrase “not-for-profit” to the daycare
facility exception contained in § 12-81 (14) was unavailing, as there was no
confusion or ambiguity regarding the term “daycare facility” as it is used
in § 12-81 (14).
The trial court was not required to apply the analysis set forth in St. Joseph’s
Living Center, Inc. v. Windham (290 Conn. 695), as it was inapplicable to
this case.
This court declined to review the defendant’s claim that permitting a tax
exemption under the present circumstances would subvert public policy by
granting an unfair advantage to nonprofit organizations to the disadvantage
of commercial landlords, as § 12-81 (14) is clear and unambiguous regarding
the exemption for daycare facilities and the application of the statute to the
facts did not yield an absurd result.
Argued September 10, 2025—officially released March 10, 2026
Procedural History
Appeal from the decision of the defendant’s board of
assessment appeals upholding the defendant’s denial of
a tax exemption for certain real property owned by the
plaintiff, brought to the Superior Court in the judicial
district of New London and transferred to the judicial

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
district of New Britain, where the case was tried to the
court, Budzik, J.; judgment sustaining the plaintiff’s
appeal, from which the defendant appealed to this court.
Affirmed.
Lloyd L. Langhammer, for the appellant (defendant).
Thomas A. Plotkin, for the appellee (plaintiff).
Opinion
WILSON, J. In this tax appeal, the defendant, the city
of Norwich, appeals from the judgment of the trial court
in favor of the plaintiff, The Lee Memorial Methodist
Church of Norwich, Connecticut, determining that a por-
tion of the property owned by the plaintiff and leased to
a daycare facility was entitled to a tax exemption under
General Statutes § 12-81 (14). On appeal, the defendant
claims that the court (1) misapplied the plain language of
§ 12-81 (14) by ignoring the fact that the plaintiff’s real
property was not used exclusively as a daycare facility,
(2) ignored the plain language of § 12-81 (7) and (14),
which requires consideration of General Statutes § 12-88,
(3) failed to apply the doctrine of noscitur a sociis in its
interpretation of § 12-81 (14), and (4) failed to apply the
analysis in St. Joseph’s Living Center, Inc. v. Windham,
290 Conn. 695, 966 A.2d 188 (2009) (St. Joseph’s), to the
tax exemption claimed in the present case. The defendant
also argues that “permitting a tax exemption under the
present circumstances would subvert public policy by
granting unfair advantage to nonprofits.” We affirm
the judgment of the court.
The court made the following findings of fact based
on the parties’ stipulations and the credible evidence
presented at trial. “At all [relevant times] . . . [the plain-
tiff] was the owner of certain real property known as 294
Washington Street in Norwich, Connecticut (church
property). Since approximately 1958, [the plaintiff] has
operated a Methodist denomination church on the church
property. [The plaintiff] is a federally tax-exempt orga-
nization. For many years, [the defendant] has approved a

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
tax exemption for [the plaintiff] and the church property
under . . . § 12-81 (12) and (13).
“In June of 2021, [the plaintiff] entered into a writ-
ten lease agreement (lease) with Creating Opportuni-
ties for Youth, LLC, doing business as Little Learners
(Little Learners) for the purpose of operating a for-profit,
licensed daycare facility and school for children. Under
the lease, Little Learners occupies a portion of the church
property (subject property) in order to provide daycare
services and school to infants and children. The daycare
facility is open five days a week (Monday–Friday) from
6:30 a.m. through 6 p.m. and two evenings per month to
accommodate parent meetings and staff training. Little
Learners is a separate business entity and is not affiliated
with [the plaintiff] (outside the lease terms). Services
provided by Little Learners at the daycare facility are not
limited to [the plaintiff’s] parishioners or its members.
“In January of 2022, [the assessor for the defendant]
informed [the plaintiff] by letter that [the defendant]
had approved a tax exemption for the church property,
excepting . . . the subject property. . . . At all [relevant
times] . . . [the plaintiff] owned the entirety of the church
property, including that portion designated herein as
the subject property. At all [relevant times] . . . the sub-
ject property was exclusively used as a daycare facility
under the terms of the lease. [The defendant] assessed
the subject property at $230,720 (or $329,600 at fair
market value).”
The plaintiff appealed the assessor’s determination to
the board of assessment appeals (board), seeking a full
tax exemption for the property. The board denied the
plaintiff’s appeal, and the plaintiff appealed to the trial
court pursuant to General Statutes § 12-117a. Follow-
ing trial, the court issued a memorandum of decision
sustaining the plaintiff’s appeal from the board’s deci-
sion. The court determined that, “[b]y its plain terms,
and as relevant to this appeal, § 12-81 (14) requires only
that exempt property be owned by a religious organiza-

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
tion and that it be used exclusively as a daycare facility.
Section 12-81 (14) includes no additional requirement
that the daycare center also be operated by the religious
organization. Because it is undisputed that the subject
property is owned by [the plaintiff], that [the plaintiff]
is a religious organization, and that the subject property
is exclusively used as a daycare facility, the court holds
that the subject property is entitled to the tax exemption
set forth in . . . § 12-81 (14).” The defendant then filed
the present appeal.
Before addressing the merits of the defendant’s claims,
we first set forth the applicable standard of review. The
meaning of § 12-81 (14) as applied to the undisputed
facts presents a question of statutory construction, over
which we exercise plenary review. See Rainbow Housing
Corp. v. Cromwell, 340 Conn. 501, 511, 264 A.3d 532
(2021). “When construing a statute, [o]ur fundamental
objective is to ascertain and give effect to the apparent
intent of the legislature. . . . In other words, we seek to
determine, in a reasoned manner, the meaning of the
statutory language as applied to the facts of [the] case,
including the question of whether the language actually
does apply. . . . In seeking to determine that meaning,
General Statutes § 1-2z directs us to first consider the
text of the statute itself and its relationship to other
statutes. If, after examining such text and considering
such relationship, the meaning of such text is plain and
unambiguous and does not yield absurd or unworkable
results, extratextual evidence of the meaning of the
statute shall not be considered. . . . When a statute is
not plain and unambiguous, we also look for interpretive
guidance to the legislative history and circumstances sur-
rounding its enactment, to the legislative policy it was
designed to implement, and to its relationship to existing
legislation and [common-law] principles governing the
same general subject matter . . . .” (Internal quotation
marks omitted.) Stanford v. Nogiec, 233 Conn. App.
862, 869–70, 342 A.3d 268, cert. denied, 353 Conn. 926,
346 A.3d 511 (2025).

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
Additionally, our review is governed by “the rule of
strict construction applicable to statutory provisions
granting tax exemptions. . . . It is . . . well established
that in taxation cases . . . provisions granting a tax
exemption are to be construed strictly against the party
claiming the exception, who bears the burden of prov-
ing entitlement to it. . . . [S]uch strict construction
neither requires nor permits the contravention of the
true intent and purpose of the statute as expressed in the
language used.” (Citation omitted; internal quotation
marks omitted.) Rainbow Housing Corp. v. Cromwell,
supra, 340 Conn. 511–12. Principally, our analysis seeks
“to ascertain and give effect to the apparent intent of
the legislature.” (Internal quotation marks omitted.)
FuelCell Energy, Inc. v. Groton, 350 Conn. 1, 6, 323
A.3d 268 (2024).
I
The defendant first claims that the court misapplied
the plain language of § 12-81 (14) because the plaintiff’s
property was not used exclusively as a daycare facility.
We disagree.
Section 12-81 (14) provides in relevant part: “Subject
to the provisions of section 12-88, real property and its
equipment owned by, or held in trust for, any religious
organization and exclusively used as a school, a daycare
facility, a Connecticut nonprofit camp or recreational
facility for religious purposes, a parish house, an orphan
asylum, a home for children, a thrift shop, the proceeds
of which are used for charitable purposes, a reformatory
or an infirmary or for two or more of such purposes” shall
be exempt from taxation.
The issue before this court is whether the subject prop-
erty is entitled to an exemption pursuant to § 12-81 (14),
subject to the provisions of § 12-88.1 The defendant
1 General Statutes § 12-88 provides in relevant part: “Real property
belonging to, or held in trust for, any organization mentioned in sub-
division . . . (14) . . . of section 12-81, which real property is so held for
one or more of the purposes stated in the applicable subdivision, and
from which real property no rents, profits or income are derived, shall

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
contends that § 12-81 (14) allows for exemptions for
“certain church related functions, like a school, a day-
care center (run by the church), a church’s thrift store,
etc.” According to the defendant, because the subject
property is used for the purpose of a for-profit daycare
facility unaffiliated with the plaintiff, the property is
not used exclusively in a manner that comports with §
12-81 (14) and, therefore, is ineligible for tax exemption
under § 12-81 (14). We disagree.
It is undisputed that the church property is owned
by the plaintiff, a religious organization, and that the
subject property is leased to Little Learners, a for-profit
daycare facility. Contrary to the contention of the defen-
dant, the subject property is exempt because it is owned
by the plaintiff and is being used exclusively as a daycare
facility in accordance with the plain language of § 12-81
(14). Section 12-81 (14) contains no requirement that
a daycare facility located on real property owned by a
religious organization also be run by or operated by that
religious organization. Simply put, the plain language of
the statute does not require that the plaintiff run the day-
care facility for the exemption to apply. By contrast, §
12-81 (14) includes requirements on real property owned
by a religious organization used as a camp or recreational
facility or as a thrift shop to receive a tax exemption.
Section 12-81 (14) specifically requires that property
used as “a Connecticut nonprofit camp or recreational
facility” be “for religious purposes . . . .” The statute
also restricts the tax exemption for property used as a
thrift shop to “a thrift shop, the proceeds of which are
used for charitable purposes . . . .”
be exempt from taxation though not in actual use therefor by reason
of the absence of suitable buildings and improvements thereon, if the
construction of such buildings or improvements is in progress. The
real property belonging to, or held in trust for, any such organization,
not used exclusively for carrying out one or more of such purposes but
leased, rented or otherwise used for other purposes, shall not be exempt.
If a portion only of any lot or building belonging to, or held in trust
for, any such organization is used exclusively for carrying out one or
more of such purposes, such lot or building shall be so exempt only to
the extent of the portion so used and the remaining portion shall be
subject to taxation.”

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
“[I]t is a basic tenet of statutory construction that
the legislature [does] not intend to enact meaningless
provisions. . . . [I]n construing statutes, we presume
that there is a purpose behind every sentence, clause,
or phrase used in an act and that no part of a statute is
superfluous.” (Internal quotation marks omitted.) Doe
v. Norwich Roman Catholic Diocesan Corp., 279 Conn.
207, 216–17, 901 A.2d 673 (2006). It is also a well settled
maxim of statutory construction that “[courts] are not
permitted to supply statutory language that the legis-
lature may have chosen to omit.” (Internal quotation
marks omitted.) Alves v. Giegler, 348 Conn. 364, 391,
306 A.3d 455 (2024). “[T]he intent of the legislature is
to be found not in what it meant to say but in what it did
say.” (Internal quotation marks omitted.) Glastonbury
Co. v. Gillies, 209 Conn. 175, 179, 550 A.2d 8 (1988).
Because § 12-81 (14) does not require that the plaintiff
be affiliated with, let alone operate, the daycare center
in order to qualify for the exemption, we decline to graft
such a requirement, otherwise omitted by the legislature,
onto § 12-81 (14).
II
The defendant next claims that the court ignored the
plain language of § 12-81 (14), which requires consider-
ation of § 12-88.2 Although we agree that § 12-81 (14)
is subject to the provisions of § 12-88, as plainly stated
within the statute, we disagree with the defendant that
the court failed to reconcile §§ 12-81 (14) and 12-88 in
its interpretation of the exemption under § 12-81 (14).
Section 12-81 (14) begins with the phrase “[s]ubject
to the provisions of section 12-88 . . . .” Section 12-88
provides in relevant part that “[r]eal property belonging
to, or held in trust for, any organization mentioned in
2 The defendant also contends, as part of this claim, that the court
ignored the plain language of § 12-81 (7). The defendant’s analysis
of § 12-81 (7), however, is included within its fourth claim on appeal,
pertaining to the exemption for charitable organizations under § 12-81
(7). We, therefore, limit our analysis of this claim to an evaluation of
the statutory relationship between § 12-88 and § 12-81 (14), and consider
the applicability § 12-81 (7) in part IV of this opinion.

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
subdivision . . . (14) . . . of section 12-81, which real prop-
erty is so held for one or more of the purposes stated in
the applicable subdivision, and from which real property
no rents, profits or income are derived, shall be exempt
from taxation though not in actual use therefor by reason
of the absence of suitable buildings and improvements
thereon, if the construction of such buildings or improve-
ments is in progress. The real property belonging to, or
held in trust for, any such organization, not used exclu-
sively for carrying out one or more of such purposes but
leased, rented or otherwise used for other purposes, shall
not be exempt. If a portion only of any lot or building
belonging to, or held in trust for, any such organization
is used exclusively for carrying out one or more of such
purposes, such lot or building shall be so exempt only
to the extent of the portion so used and the remaining
portion shall be subject to taxation.”
Our interpretation of §§ 12-81 (14) and 12-88 is guided
by Isaiah 61:1, Inc. v. Bridgeport, 270 Conn. 69, 76,
79–80, 851 A.2d 277 (2004) (Isaiah 61:1), in which our
Supreme Court considered whether certain property
owned by the plaintiff, Isaiah 61:1, Inc., and used to
house, rehabilitate, and counsel inmates completing the
final months of their sentences, qualified for tax-exempt
status under § 12-81 (7).3 Id., 70–72. The defendant
city claimed that the plaintiff’s property did not qualify
for tax-exempt status under § 12-81 (7) because, inter
alia, the inmates occupying the premises paid rent to
the plaintiff. Id., 74. The Supreme Court disagreed and
concluded that the plaintiff’s receipt of rent from the
resident inmates did not undermine the exclusive use of
the property for charitable purposes. Id., 75. Similar to
the defendant’s argument in Isaiah 61:1, the defendant
in the present case argues that the subject property,
3 General Statutes § 12-81 provides in relevant part: “The following-
described property shall be exempt from taxation . . . (7) (A) Subject
to the provisions of sections 12-87 and 12-88, the real property of, or
held in trust for, a corporation organized exclusively for scientific,
educational, literary, historical or charitable purposes or for two or
more such purposes and used exclusively for carrying out one or more
of such purposes . . . .”

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
for which the plaintiff collects rental payments, should
not be exempt. Although the present case involves an
exemption sought pursuant to § 12-81 (14), rather than §
12-81 (7), we find the court’s interpretation of § 12-88 in
Isaiah 61:1 persuasive regarding whether the plaintiff’s
receipt of rent renders the subject property ineligible for
an exemption under § 12-81 (14).
As stated in Isaiah 61:1, “[p]roperty otherwise exempt
from taxation under § 12- 81 (7) also must satisfy the
conditions set forth in . . . § 12-88, which provides in rel-
evant part: ‘Real property belonging to, or held in trust
for, any organization mentioned in subdivision (7) . . . of
section 12-81, which real property is so held for . . . the
purposes stated in the applicable subdivision . . . shall be
exempt from taxation . . . . The real property belonging
to . . . any such organization . . . not used exclusively
for carrying out . . . such purposes but leased, rented or
otherwise used for other purposes, shall not be exempt.
. . .’ ” (Emphasis in original.) Id., 76. “Thus, in order for
real property used for charitable purposes to qualify for
tax exemption under §§ 12-81 (7) and 12-88, the property
must: (1) belong to or be held in trust for a corporation
organized exclusively for charitable purposes; (2) be used
exclusively for carrying out such charitable purposes;
(3) not be leased, rented or otherwise used for a purpose
other than the furtherance of its charitable purposes
. . . .” Id., 76–77.4
The court in Isaiah 61:1 cited with approval its decision
in Hartford Hospital v. Hartford, 160 Conn. 370, 279
A.2d 561 (1971), in which the court considered whether
the plaintiff hospital was entitled to a tax exemption
for an apartment building that it owned adjacent to the
hospital that was used exclusively to house hospital staff,
4 In addition, in order to qualify for a tax exemption under §§ 12-81 (7)
and 12-88, the property must not be housing subsidized by the govern-
ment and must not constitute low-income or moderate-income housing.
See Isaiah 61:1, Inc. v. Bridgeport, supra, 270 Conn. 77. As there is no
claim that the subject property in the present case is “housing” as that
term is ordinarily understood, we limit our analysis to the first three
prongs set forth in Isaiah 61:1.

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
all of whom paid rent to the hospital. Citing Hartford
Hospital, the court in Isaiah 61:1 “noted that the second
sentence of . . . § 12-88, which provides that an organi-
zation’s property that is not used exclusively for carry-
ing out the organization’s purposes but that is leased,
rented or otherwise used for other purposes, shall not
be exempt, was the key sentence of [the statute] . . . and
state[d] the basic premise upon which an exemption may
be denied. . . . We determined that, under § 12-88, prop-
erty belonging to or held in trust for a hospital which is
used exclusively for carrying out hospital purposes shall
be exempt. If the property is leased, rented or used for
anything other than hospital purposes [however] it shall
not be exempt. The determining factor is the exclusive
use of the property for hospital purposes. The distinc-
tion is not between nonrental and rental but between
use exclusively for hospital purposes and nonhospital
use. The third sentence of § 12-88 exempts from taxa-
tion any portion of a lot or building used exclusively for
hospital purposes even though the remaining portion
shall be subject to taxation. This serves to emphasize
our construction of the second sentence that the basic
question is whether the use was exclusively for hospital
purposes or for some other purpose. . . . [T]he fact that
certain sums are paid for use of the rooms occupied . . .
does not alter the character of the occupation.” (Citations
omitted; internal quotation marks omitted.) Isaiah 61:1,
Inc. v. Bridgeport, supra, 270 Conn. 79–80.
Consistent with the court’s analysis in Isaiah 61:1,
therefore, we conclude that, in order for real property
used as a daycare facility to qualify for tax exemption
under §§ 12-81 (14) and 12-88, the property must: (1)
belong to or be held in trust for a religious organization;
(2) be exclusively used as a daycare facility; and (3) not be
leased, rented or otherwise used for a purpose other than
a daycare facility. See id., 76–77; see also St. Joseph’s
Living Center, Inc. v. Windham, supra, 290 Conn. 709.
In the present case, the subject property is owned by
the plaintiff, a religious organization, is exclusively
used as a daycare facility, and is leased in furtherance

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
of the purpose intended under § 12-81 (14), namely, as
a daycare facility.
We note the defendant’s reliance to the contrary on
the language “and from which real property no rents,
profits or income are derived” in the first sentence of §
12-88. The defendant contends that, pursuant to this
language, the subject property should not be exempt.
The defendant’s reliance on this language, however, is
misplaced. In St. Joseph’s Living Center, Inc. v. Wind-
ham, supra, 290 Conn. 728, our Supreme Court clarified
what it called the often “misunderstood and misapplied”
passage of § 12-88 relating to rents, profits or income.
The court in St. Joseph’s explained that several courts
had taken the clause “[r]eal property belonging to . . . any
organization mentioned in subdivision (7) . . . of section
12-81 . . . and from which real property no rents, profits
or income are derived, shall be exempt from taxation”
out of context, grafting onto the tax exemption analysis
a requirement that the property for which exemption is
sought produce “no rent, profits or income.” (Internal
quotation marks omitted.) Id., 728–29.
As explained in St. Joseph’s, “this provision is directly
subordinate to the following clause of the statute: ‘though
not in actual use therefor by reason of the absence of suit-
able buildings and improvements thereon, if the construc-
tion of such buildings or improvements is in progress.’ . .
. Thus, when the statute is read in its entirety, it makes
clear that the restriction relating to ‘rents, profits or
income’ is only relevant if the property is not being used
for a charitable or other exempt purpose ‘by reason of the
absence of suitable buildings and improvements thereon,
if the construction of such buildings or improvements is
in progress.’ . . . Unless such a specific claim is raised,
this portion of § 12-88 simply is irrelevant to the analysis
under § 12-81 (7).” (Citations omitted.) Id., 729. For
the reasons set forth in St. Joseph’s, we conclude that
the language “and from which real property no rents,
profits or income are derived” in the first sentence of §
12-88 is not relevant to our analysis under § 12-81 (14).

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
The trial court, therefore, did not ignore the plain lan-
guage of § 12-81 (14), and properly considered § 12-88,
in concluding that the subject property was entitled to
a tax exemption pursuant to § 12-81 (14).
III
The defendant next claims that the court erred by
failing to apply the principle of noscitur a sociis5 in its
interpretation of § 12-81 (14). Specifically, the defen-
dant contends that, because the exempt uses listed in
§ 12-81 (14) are traditionally maintained by religious
organizations, the legislature could not have intended
that a daycare facility would include a for-profit entity
leasing property from the church. We disagree.
The defendant essentially contends that the court
should have applied the principle of noscitur a sociis
to add the words “not-for-profit” to the daycare cen-
ter exemption in § 12-81 (14). It is true that, “[w]hen
determining the legislature’s meaning of a statutory
word, it is . . . appropriate to consider the surrounding
words pursuant to the canon of construction noscitur
a sociis. . . . By using this interpretive aid, the mean-
ing of a statutory word may be indicated, controlled or
made clear by the words with which it is associated in the
statute.” (Citation omitted; footnote omitted.) Balloli
v. New Haven Police Dept., 324 Conn. 14, 23, 151 A.3d
367 (2016); see also DATTCO, Inc. v. Commissioner of
Transportation, 324 Conn. 39, 48, 151 A.3d 823 (2016)
(when statute includes list or group of related words,
application of noscitur a sociis doctrine permits meaning
of particular word or phrase to be ascertained by refer-
ence to associated words or phrases).
We initially note that the cases that have applied the
principle of noscitur a sociis have done so to clarify the
meaning of a single word or phrase within a statute
by examining the words with which it is associated in
5 Noscitur a sociis means “it is known by its associates.” (Internal
quotation marks omitted.) State v. Agron, 323 Conn. 629, 635 n.3,
148 A.3d 1052 (2016).

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
the statute. See, e.g., DATTCO, Inc. v. Commissioner
of Transportation, supra, 324 Conn. 48 (grouping of
term “facilities” in General Statutes § 13b-36 (a) with
other nouns that each denote tangible objects, including
land, buildings, and equipment, favors conclusion that
term “facilities” also refers to tangible objects, and did
not include government issued certificate of use (inter-
nal quotation marks omitted)); Balloli v. New Haven
Police Dept., supra, 324 Conn. 22–23 (construing phrase
“place of abode” in General Statutes § 31-275 (1) (A) (i)
in relationship to associated terms). In the present case,
however, there is no need for clarification as there is no
confusion or ambiguity regarding the term “daycare
facility” as it is used in § 12-81 (14).
Furthermore, the defendant overlooks the “principle
of statutory construction that a court must construe a
statute as written. . . . Courts may not by construction
supply omissions . . . or add exceptions merely because
it appears that good reasons exist for adding them. . . .
The intent of the legislature, as this court has repeatedly
observed, is to be found not in what the legislature meant
to say, but in the meaning of what it did say. . . . It is
axiomatic that the court itself cannot rewrite a statute
to accomplish a particular result. That is a function of
the legislature.” (Internal quotation marks omitted.)
Doe v. Norwich Roman Catholic Diocesan Corp., supra
279 Conn. 216.
The defendant, therefore, cannot prevail on its claim
that the court erred by failing to apply the principle of
noscitur a sociis to supply the phrase “not-for-profit” to
the daycare center exemption contained in § 12-81 (14).
IV
The defendant next claims that the court failed to
apply the analysis in St. Joseph’s Living Center, Inc. v.
Windam, supra, 290 Conn. 695, to the tax exemption
claimed in the present case. We disagree and conclude,
for the reasons that follow, that it was unnecessary for

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
the court to apply the framework set forth in St. Joseph’s
in the present case.
In St. Joseph’s, our Supreme Court considered whether
the defendant town properly had denied the plaintiff,
a skilled nursing home facility, a property tax exemp-
tion under § 12-81 (7)6 and § 12-88. Id., 697. The court
began its analysis by stating that “[t]he first statutory
requirement . . . for tax-exempt status under §§ 12-81
(7) and 12-88 is that the property must belong to or be
held in trust for a corporation organized exclusively for
charitable purposes.” (Citation omitted; internal quota-
tions omitted.) Id., 712–13. The court next considered
the second step in its analysis under § 12-81 (7), namely,
“whether the real property at issue [was] used exclusively
for carrying out [the corporate entity’s] charitable pur-
poses.” (Internal quotation marks omitted.) Id., 740.
The court stated that “the exclusive use requirement of
§ 12-81 (7) must be strictly construed so as to require a
charitable organization seeking the benefit of a property
tax exemption to use its property in such a manner that
its activities are entirely dedicated to serving its stated
charitable purpose.” Id., 745.
The defendant argues that the court should have
applied the analytical framework set forth in St. Joseph’s
to the present facts. Doing so, the defendant contends,
will demonstrate that the use of the plaintiff’s property
by a for-profit entity unaffiliated with the plaintiff is a
noncharitable use and, therefore, the property at issue
is ineligible for tax exemption under § 12-81 (14). While
we agree with the defendant that St. Joseph’s provides
the proper analysis for determining whether a charitable
organization is exempt under § 12-81 (7), we disagree that
St. Joseph’s applies to our consideration of whether the
subject property of the plaintiff, a religious organization,
which is exclusively used as a daycare facility, is entitled
to an exemption under § 12-81 (14).
It is undisputed that the plaintiff is incorporated as a
religious organization, not as a charitable corporation.
6 See footnote 3 of this opinion.

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
The plaintiff sought a tax exemption pursuant to § 12-81
(14) for the portion of property being exclusively used as
a daycare facility, not an exemption pursuant to § 12-81
(7) for property belonging to a charitable corporation
and used exclusively for a charitable purpose.7 Unlike
§ 12-81 (7), which requires that the real property of a
charitable corporation be “used exclusively” for carrying
out the organization’s charitable purposes, § 12-81 (14)
requires only that the exempt property be “exclusively
used as a . . . daycare facility.” Section 12-81 (14) does
not require that the exempt property be used exclusively
for a charitable purpose. The analysis of § 12-81 (7)
contained in St. Joseph’s, therefore, is not applicable to
this case, which involves a claimed exemption pursuant
to § 12-81 (14). For these reasons, the defendant cannot
prevail on its claim that the court should have applied
the analytical framework set forth in St. Joseph’s to the
present case to conclude that the plaintiff is not entitled
to an exemption pursuant to § 12-81 (14).
V
The defendant’s final claim is that permitting a tax
exemption under the present circumstances would sub-
vert public policy by granting an unfair advantage to non-
profit organizations to the disadvantage of commercial
landlords. Because § 12-81 (14) is clear and unambiguous
regarding the exemption for daycare facilities, and the
application of the statute to the facts of this case does
7 The record reflects that the plaintiff initially sought, in its amended
appeal from the board, a declaration that the subject property was fully
exempt from taxation under § 12-81 (7) (A) and (14). It later narrowed its
focus, stating in its trial memorandum that, “[a]s a religious organiza-
tion, the plaintiff qualifies for a tax exemption under § 12-81 (13) and
(14). The plaintiff is also a charitable organization and may qualify for
a tax exemption pursuant to § 12-81 (7), but subdivisions (13) and (14)
more appropriately apply.” Moreover, as previously noted, for many
years the defendant has approved a tax exemption for the plaintiff and
the church property under § 12-81 (12) and (13). Furthermore, the trial
court’s memorandum of decision does not reference a claimed exemp-
tion under § 12-81 (7). The issue of whether the plaintiff was entitled
to an exemption under § 12-81 (7) is therefore extraneous to our review
of the court’s judgment.

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
not yield an absurd result, it is unnecessary for us to
consider the defendant’s public policy claim.8
As stated previously in this opinion, if the meaning
of a statute is plain and unambiguous and does not yield
absurd or unworkable results, extratextual evidence of
the meaning of the statute shall not be considered. When
a statute is not plain and unambiguous, however, “we also
look for interpretive guidance to the legislative history
and circumstances surrounding its enactment, to the
legislative policy it was designed to implement, and to
its relationship to existing legislation and [common-law]
principles governing the same general subject matter
. . . .” (Internal quotation marks omitted.) Stanford v.
Nogiec, supra, 233 Conn. App. 870.
As discussed in this opinion, the subject property is
owned by the plaintiff, a religious organization. It is used
exclusively as a daycare facility and is leased in further-
ance of the purpose intended under § 12-81 (14), namely,
as a daycare facility. Under these circumstances, § 12-81
(14) unambiguously provides that the subject property
is exempt from taxation. Because the statute is clear
and unambiguous regarding the exemption for daycare
facilities, and the application of the statute to the facts
of this case does not yield an absurd result, we decline
the defendant’s invitation to consider extratextual evi-
dence regarding legislative policy behind the daycare
exemption. “[I]t is well established that the primary
responsibility for formulating public policy must remain
8 We note that the defendant’s analysis of this claim is one paragraph
and consists primarily of conclusory assertions without citation to rel-
evant legal authority. Accordingly, this claim is not adequately briefed.
See Hadji v. Snow, 232 Conn. App. 829, 861–62, 339 A.3d 1168, cert.
denied, 353 Conn. 902, 341 A.3d 958 (2025). Nevertheless, even assum-
ing that this claim is adequately briefed, we do not find persuasive the
defendant’s argument that application of the plain language of the
statute yields a result that unfairly benefits organizations such as the
plaintiff to the detriment of commercial landlords. One may reasonably
view our interpretation of the statute to yield a result consistent with
the public good in that it incentivizes the operation of daycare facilities
in areas in which they are needed, regardless of whether they are run
by religious or for-profit entities.

Lee Memorial Methodist Church of Norwich, Connecticut v. Norwich
with the legislature.” (Internal quotation marks omit-
ted.) Adesokan v. Bloomfield, 347 Conn. 416, 446–47,
297 A.3d 983 (2023). “Once the legislature has made
its policy choice through statute, we are constrained to
interpret the statutory language, not to decide on and
implement our own policy choices.” Id., 447.
The judgment is affirmed.
In this opinion the other judges concurred.