Justia District of Columbia Court of Appeals Opinion Summaries

The case involves a dispute between two neighbors residing in the same apartment building in Washington, D.C. The petitioner alleged that the respondent had stolen food deliveries from her apartment door on two occasions and, on two other occasions, had knocked on her bedroom window early in the morning and made crude sexual propositions. The petitioner testified about her fear and referenced the respondent’s status as a registered sex offender. Video evidence of the food thefts was presented, and the respondent’s counsel argued that the alleged conduct did not meet the statutory requirements for stalking and that the sexual statements constituted protected speech under the First Amendment.The case was initially reviewed by the Superior Court of the District of Columbia. The trial court found that the respondent had engaged in a course of conduct meeting the statutory definition of stalking, relying on both the food thefts and the window-knocking incidents, including the sexual propositions. The court granted the petitioner an anti-stalking order, reasoning that the combination of food theft and unwanted sexual advances constituted the type of targeting that the anti-stalking statute was intended to prevent.On appeal, the District of Columbia Court of Appeals reversed the trial court’s decision. The appellate court held that the trial court erred by failing to consider whether the respondent’s speech was constitutionally protected and may not be punished as stalking, as required by Mashaud v. Boone, 295 A.3d 1139 (D.C. 2023). Because the trial court relied on the content of protected speech and did not conduct the necessary First Amendment analysis, the error was deemed harmful. The anti-stalking order was reversed and the case was remanded for further proceedings consistent with this opinion. View "Graham v. T.T." on Justia Law

A passenger at a metro station, who was noticeably intoxicated, accidentally fell from the station platform into a non-public area—a trough housing electrical equipment—after stumbling and attempting to sit on a narrow parapet. The fall resulted in immobilizing injuries that compromised his breathing. Although the station manager was required by operating procedures to perform visual inspections of the platform at set intervals, it is disputed whether those inspections were performed and whether they included checking behind the parapet. The passenger remained undiscovered for four days and died from asphyxiation. Experts opined he would have survived if found and aided promptly.The decedent’s parents and estate sued the transit authority for negligence and wrongful death in the United States District Court for the District of Columbia, arguing that the authority’s failure to discover and aid him aggravated his injuries and led to his death. The district court initially denied summary judgment for the transit authority, but later granted it on the grounds of contributory negligence, finding the decedent’s intoxication and actions barred recovery as a matter of law. On appeal, the United States Court of Appeals for the District of Columbia Circuit reversed and remanded, holding that under District law, common carriers owe passengers a duty of care even where contributory negligence is present, but recognizing uncertainty as to whether this duty applies once a passenger becomes a trespasser by entering a non-public area involuntarily.The District of Columbia Court of Appeals, answering a certified question from the D.C. Circuit, held that a passenger who unintentionally enters a non-public area becomes a trespasser. However, if the common carrier knows or has reason to know the trespasser is injured, trapped, or imperiled, it owes a duty of ordinary care—including a reasonable duty to aid—to prevent further injury. This duty is fact-specific and does not arise for undiscovered trespassers. View "Whiteru v. Washington Metropolitan Area Transit Authority" on Justia Law

Late one night in January 2019, three men—Sean Shuler, Javon Abney, and Tyrik Hagood—were shot and killed on a street in Southeast Washington, D.C. Rakeem Willis and Jonathan Winston were charged with three counts of first-degree (premeditated) murder in connection with these deaths. Evidence at trial included eyewitness accounts, forensic findings, and extensive cell phone records, including historical cell site location information (CSLI) used to trace phone movements. The government presented FBI Special Agent Billy Shaw as an expert to interpret the CSLI data, linking Willis’s phones to the vicinity of the crime and subsequent locations.Prior to trial, Winston moved to exclude the CSLI expert’s report and testimony, arguing the government’s notice was insufficient under Superior Court Rule of Criminal Procedure 16 and that the methodology lacked reliability as required by Motorola Inc. v. Murray and Federal Rule of Evidence 702. The motions court admitted the expert testimony over objections, relying on prior experience and cross-examination as safeguards, and declined to hold a Daubert hearing. The trial court later granted Winston’s motion for judgment of acquittal, but Willis was convicted by a jury of all three murder counts and sentenced to 120 years in prison.On appeal, the District of Columbia Court of Appeals found that the motions court failed to properly exercise its gatekeeping role under Rule 702 and Motorola by not sufficiently evaluating whether the expert had reliably applied CSLI methodology to the facts. The appellate court held this error was not harmless, given the centrality of the expert testimony to the government’s case. It therefore reversed Willis’s first-degree murder convictions and remanded for further proceedings. View "Willis v. United States" on Justia Law

Several individuals challenged the validity of the District of Columbia’s Anti-SLAPP Act, which provides defendants in certain lawsuits—those deemed “strategic lawsuits against public participation” (SLAPPs)—with a special motion to dismiss and limits discovery in those cases. The challengers argued that the D.C. Council exceeded its authority under the Home Rule Act by enacting the Anti-SLAPP Act, claiming that its discovery-limiting provisions impermissibly intruded on the procedural rules governing the Superior Court of the District of Columbia, which are set by Title 11 of the D.C. Code.A division of the District of Columbia Court of Appeals previously agreed with the challengers, holding that the Anti-SLAPP Act’s discovery provisions violated the Home Rule Act by interfering with Title 11’s mandate that the Superior Court follow the Federal Rules of Civil Procedure, except as modified by the courts themselves. The division’s decision was subsequently vacated when the full court granted en banc review.The District of Columbia Court of Appeals, sitting en banc, reversed the division’s decision. The court held that the D.C. Council did not exceed its authority under the Home Rule Act by passing the Anti-SLAPP Act. The court reasoned that the Act does not amend Title 11, does not alter the organization or jurisdiction of the District’s courts, does not divest the courts of their rulemaking authority, and does not fundamentally change the court system. Instead, the Act supplements procedures for a limited subset of cases in a manner consistent with Title 11. The court concluded that the Council’s broad legislative authority includes the power to enact such laws, and that the Anti-SLAPP Act does not violate the Home Rule Act. The case was remanded for further proceedings consistent with this opinion. View "Banks v. Hoffman" on Justia Law

In 2001, Joseph Jackson, then twenty years old, was involved in a drug-related conflict in southeast Washington, D.C. After being told by a rival dealer, Larry Smith, that he could no longer sell drugs in the area, Jackson instructed his associate, Troy Ashley, to “handle that.” Ashley, with the help of Jason Parker, confronted Smith and his associates, resulting in Ashley shooting and killing Smith and robbing and shooting the other two men. Ashley and Parker reported back to Jackson, who expressed excitement and rewarded Parker with drugs. Jackson was subsequently convicted by a jury in 2003 of first-degree premeditated murder, armed robbery, and other offenses.The District of Columbia Court of Appeals previously affirmed Jackson’s convictions and remanded for merger of offenses and resentencing, after which Jackson received a thirty-five-year prison term. In 2023, Jackson moved in the Superior Court of the District of Columbia for a sentence reduction under the Incarceration Reduction Amendment Act (IRAA), arguing that he had matured and was no longer dangerous. The government opposed, citing Jackson’s extensive record of violent and nonviolent disciplinary infractions during incarceration, including assaults and possession of contraband. The Superior Court found Jackson met the threshold for IRAA consideration but, after reviewing the statutory factors, determined that his continued infractions and lack of rehabilitation weighed against sentence reduction. The court denied the motion, finding Jackson remained a danger and that the interests of justice did not warrant modification.The District of Columbia Court of Appeals reviewed the denial for abuse of discretion. The court held that the Superior Court properly considered the relevant IRAA factors, including Jackson’s personal circumstances and role in the offense, and found no error in its analysis. The appellate court affirmed the Superior Court’s order denying Jackson’s motion for sentence reduction. View "Jackson v. United States" on Justia Law

Alexander Zajac was employed by Finnegan, Henderson, Farabow, Garrett & Dunner, LLP from August 2016 to March 2020, first as a Student Associate and later as an Associate Attorney. His initial offer letter outlined salary, eligibility for bonuses, and tuition reimbursement conditions, but stated it was not a contract. Zajac alleged that, despite billing over 2200 hours in 2019, he did not receive a productivity bonus, and that his tuition reimbursement was not paid in full as promised. He claimed oral assurances were made regarding mandatory bonuses and post-tax tuition reimbursement, and that these benefits were standard practice at the firm.After unsuccessful administrative efforts, Zajac filed a complaint in the Superior Court of the District of Columbia in March 2023, alleging wage theft under the D.C. Wage Payment and Collection Law (DCWPCL) for both the productivity bonus and tuition reimbursement. Finnegan moved to dismiss, arguing the payments were discretionary and not “wages” under the DCWPCL. The trial court granted the motion to dismiss, finding the bonus discretionary and the tuition reimbursement an expense, not a wage. The court allowed Zajac to seek leave to amend his complaint. Zajac filed a motion for leave to amend, asserting additional facts about oral promises and customary practices. The trial court denied leave, reasoning the amended complaint contradicted the original and did not cure its defects.The District of Columbia Court of Appeals reviewed the case. It affirmed the dismissal of the original complaint, as Zajac conceded its vagueness. However, the appellate court held that the trial court abused its discretion by denying leave to amend based solely on alleged contradictions, without considering all relevant factors. Applying de novo review, the appellate court found the amended complaint stated plausible claims of wage theft for both the productivity bonus and tuition reimbursement. The judgment was reversed and remanded for further proceedings. View "Zajac v. Finnegan, Henderson, Farabow, Garrett & Dunner, LLP" on Justia Law

Eckington House Mental Health Services, LLC provides supportive living and personal care services for individuals with intellectual and developmental disabilities, employing a pool of Direct Support Professionals (DSPs). Regina Kennedy worked as a DSP for Eckington from August 2020 to May 2021. She filed a complaint with the Office of Wage-Hour (OWH) alleging that she worked more than forty hours per week from November 2020 through May 2021 but was not paid overtime wages.The Office of Wage-Hour issued a Revised Initial Determination finding that Eckington violated the District of Columbia Minimum Wage Act (DCMWA) by failing to pay Kennedy overtime wages. OWH determined that Eckington owed Kennedy $3,011.75 in unpaid overtime wages and $9,035.25 in liquidated damages, and assessed a $22,850 penalty to be paid to the District. Eckington appealed to the Office of Administrative Hearings (OAH), where an Administrative Law Judge (ALJ) upheld the findings regarding unpaid wages and damages but reversed the penalty assessment due to insufficient evidence supporting the penalty. Eckington then petitioned for review by the District of Columbia Court of Appeals.The District of Columbia Court of Appeals reviewed the ALJ’s findings for substantial evidence and legal conclusions de novo. The court held that the ALJ properly applied the “economic reality” test to determine employee status under the DCMWA, considering factors such as control, opportunity for profit or loss, investment in equipment, skill required, duration of relationship, and the integral nature of the work. The court found substantial evidence supporting the ALJ’s conclusion that Kennedy was an employee, not an independent contractor, and affirmed the award of unpaid overtime wages and liquidated damages. The court also declined to consider Eckington’s argument regarding the professional services exemption, as it was not raised before OAH. The OAH’s order was affirmed. View "Eckington House Mental Health Services, LLC v. Office of Wage Hour" on Justia Law

Petronella McKenzie sought a second extension of a Civil Protection Order (CPO) against her former husband, Paul Persaud, alleging ongoing fear and past abuse. The parties had previously lived together in Guyana, where Ms. McKenzie testified to experiencing sexual, physical, and emotional abuse. After relocating, she obtained a CPO on consent in February 2020, which was later modified due to threats and extended in 2021 following technical violations by Mr. Persaud. Ms. McKenzie argued that her continued fear, the contentious nature of an ongoing custody case, and changes in visitation arrangements for their child supported her request for another extension.The Superior Court of the District of Columbia reviewed Ms. McKenzie’s motion for a second extension. The trial judge considered transcripts from prior hearings, Ms. McKenzie’s testimony about her relationship with Mr. Persaud, and evidence from the custody case. The court acknowledged the history of abuse and threats, as well as Ms. McKenzie’s ongoing fear. However, it found that since the last extension, Mr. Persaud had not committed further violations or demonstrated a current danger to Ms. McKenzie. The court concluded that the evidence did not establish good cause for a second extension of the CPO.The District of Columbia Court of Appeals reviewed the denial of the extension. The court held that the trial court did not misconstrue the legal standard for “good cause” under D.C. Code § 16-1005(d-1), properly considered the “entire mosaic” of the parties’ relationship, and made sufficient factual findings. The appellate court found no abuse of discretion and affirmed the trial court’s decision to deny the second extension of the CPO. View "McKenzie v. Persaud" on Justia Law

In October 2022, a man crashed his car into a parked vehicle in southeast Washington, D.C. After the collision, the car’s owner confronted him, and as police arrived, the man fled on foot. Officers pursued and apprehended him, discovering a gun with a large-capacity magazine under a vehicle along his escape route and another large-capacity magazine with ammunition inside his car. He was charged with several firearm-related offenses, including possession of a large-capacity ammunition feeding device and unlawful possession of ammunition.The Superior Court of the District of Columbia denied the defendant’s motions to dismiss the large-capacity magazine charges on Second Amendment grounds and to suppress the evidence found at the scene, ruling that the search and seizure were justified. After a jury trial, he was convicted of one count of possession of a large-capacity ammunition feeding device and one count of unlawful possession of ammunition, both based on the magazine found in his car. He was acquitted of other charges. The defendant appealed, challenging the denial of suppression, the sufficiency of the evidence for the large-capacity magazine conviction, the lack of a jury instruction on knowledge, and the constitutionality of the statute.The District of Columbia Court of Appeals reviewed the case. After oral argument, the government moved to vacate the large-capacity magazine conviction due to a change in its position on the statute’s constitutionality, which the court granted. The court affirmed the denial of suppression and upheld the unlawful possession of ammunition conviction, holding that the officers’ entry into the car to seize the magazine was justified under the automobile exception to the warrant requirement, as they had probable cause to believe the car contained evidence of criminal activity. The case was remanded for further proceedings. View "Miller v. United States" on Justia Law

A defendant, who was sixteen and seventeen years old at the time of two separate armed robberies in Washington, D.C., pleaded guilty to charges arising from those incidents. In the first case, he used a BB gun resembling a real firearm and was sentenced under the Youth Rehabilitation Act (YRA) to probation. While on probation, he committed a second robbery with an actual firearm and was sentenced to imprisonment and supervised release, not under the YRA. After completing all sentences and supervision, he moved to have both convictions set aside under a provision of the YRA that allows for such relief after completion of sentence, based on a set of statutory factors.The Superior Court of the District of Columbia denied both motions. The court found that several statutory factors weighed against the defendant, including the violent nature of the offenses, the fact that the second offense was committed while on supervision for the first, and a later temporary protective order issued against him. The court treated the defendant’s age at the time of the offenses as merely establishing eligibility for YRA relief, did not weigh in his favor the lack of prior YRA sentencing for the first conviction, and interpreted the factor regarding the ability to appreciate risks and consequences as relating to acceptance of responsibility after the fact.On appeal, the District of Columbia Court of Appeals held that the trial court erred in its application of the statutory factors. Specifically, the appellate court found that the trial court misapplied the factors concerning the defendant’s age, prior YRA sentencing, and ability to appreciate risks and consequences. The appellate court vacated the trial court’s order and remanded the case for reconsideration of the motions to set aside the convictions, instructing the lower court to apply the statutory factors correctly. View "Williams v. United States" on Justia Law