May a landlord evict a tenant at sufferance for nonpayment of rent?

Winfield Elwell orally agreed to rent an apartment in Vernon, Connecticut, to Lucille Minor on a month-to-month basis. The rent was $575. Four years later, Elwell increased the rent to $625, and the next year to $650, taking effect that September. Minor tendered $625 and included a letter explaining that she did not want to pay the increased rent for September or October but that she would pay the increase in later months. Elwell rejected the payment. Minor then tendered the check a second time, and Elwell again returned it.
Elwell told Minor to pay $650 or vacate. She did neither, so Elwell began eviction proceedings (called “summary process”) by serving on Minor a Notice to Quit for nonpayment of rent. After additional negotiations failed, Elwell served a second Notice to Quit. At trial, Minor argued that nonpayment of rent was an improper grounds for evicting a tenant at sufferance. She asked the court to dismiss the case.