Justia District of Columbia Court of Appeals Opinion Summaries

In December 2021, Brian C. Carruth drove from Ohio to Washington, D.C., with a rifle and ammunition in his pickup truck. The rifle was stored in a padlocked case, and Carruth had removed its firing pin and bolt, rendering it inactive. Upon being stopped by police, Carruth initially denied having a weapon but later admitted to possessing the rifle. The rifle was not registered in D.C., and Carruth did not have a valid registration certificate for the ammunition. He was charged with carrying a rifle in the District, possession of an unregistered firearm, and unlawful possession of ammunition.After a jury trial in the Superior Court of the District of Columbia, Carruth was convicted on all charges. During trial, the court ordered Carruth not to discuss the substance of his testimony with his lawyer during a lunch break, which Carruth objected to as a violation of his Sixth Amendment rights. On appeal, Carruth contested the sufficiency of evidence for the rifle-carrying conviction, challenged the constitutionality of the relevant statute under the Second Amendment, and alleged a Sixth Amendment violation due to the trial court’s order. The United States, initially opposing Carruth’s arguments, moved to vacate the rifle-carrying conviction based on its new stance that the statute was unconstitutional. The District of Columbia did not oppose the motion, though it maintained the statute’s constitutionality. The Public Defender Service, as amicus, argued for a merits resolution.The District of Columbia Court of Appeals granted the government’s unopposed motion to vacate the rifle-carrying conviction, remanded for further proceedings, and affirmed Carruth’s convictions for possessing an unregistered firearm and ammunition. The court held that the trial court’s order barring Carruth from discussing the substance of his testimony during a brief recess did not violate his Sixth Amendment right to counsel, applying the Supreme Court’s decision in Villarreal v. Texas. View "Carruth v. United States" on Justia Law

The appellant was arrested and held in pretrial detention for over a year before being indicted for first-degree murder. He argued for his immediate release, claiming the prosecution had "abandoned" its case by failing to indict him within the nine-month period specified by D.C. Code § 23-102. That provision states that if a grand jury does not act within nine months, the prosecution is deemed abandoned and the accused should be released. The appellant sought either release or dismissal of the indictment, acknowledging that a grand jury could later reindict him.The Superior Court of the District of Columbia reviewed the appellant’s request for release. The trial court denied the motion, reasoning that defense counsel had agreed to extend the statutory nine-month period and that agreement was binding on the appellant. After the appellant appealed this ruling, a grand jury indicted him for first-degree murder. Subsequently, the appellant requested dismissal of the indictment and release from detention.The District of Columbia Court of Appeals reviewed the case and determined it had jurisdiction to hear the appeal, finding that it was not moot. The court held that, even if the appellant had been detained beyond the nine-month window without proper authorization to toll the period, the only remedy provided by D.C. Code § 23-102 is release from detention, not dismissal of an indictment. Once an indictment is returned, release is not available under the statute. The court also declined to remand for an evidentiary hearing regarding counsel’s authority to toll the period, as it would not lead to any relief. Therefore, the court affirmed the trial court’s order denying the appellant’s request. View "Jones v. United States" on Justia Law

Appellants, owners of rowhouses abutting a proposed residential development in Washington, D.C., challenged the actions of the D.C. Zoning Commission regarding the approval of a Design Review application submitted by a developer. Their properties shared an easement with the development site, and a prior agreement in 2017 and a subsequent one in 2022 set the terms of access. During the Commission’s public hearing, both Appellants and Developer discussed the easement, with Developer assuring that the agreement was signed, though not yet recorded. Appellants voiced concerns about the easement’s finality and requested further review.After the Commission approved the Design Review application and issued its Order of Approval, Appellants pursued separate legal actions against the Developer, which were dismissed following the new easement agreement. Subsequently, Appellants filed a complaint against the District of Columbia in the Superior Court of the District of Columbia, claiming violations of their substantive due process rights under 42 U.S.C. § 1983. They alleged the Commission deliberately ignored statutory requirements by failing to collect their signatures for the application and by neglecting to properly investigate the easement’s final status.The Superior Court dismissed the complaint, citing lack of subject matter jurisdiction due to Appellants’ failure to exhaust administrative remedies, and also found that Appellants failed to state a viable due process claim. On appeal, the District of Columbia Court of Appeals determined that dismissal for lack of subject matter jurisdiction was improper, as exhaustion of administrative remedies is not a jurisdictional requirement. However, the Court affirmed the dismissal for failure to state a claim, concluding that Appellants’ allegations amounted at most to negligence, not the egregious conduct required for a substantive due process violation. The judgment of the Superior Court was affirmed. View "Samaddar, DDS v. District of Columbia" on Justia Law

Late one night, three police officers responding to a report of a recent nearby shooting observed a man walking on the street. The man appeared to have an L-shaped bulge in his right jacket pocket, which the officers believed could be a firearm. When the officers pulled their marked cruiser alongside him and asked if he had a gun, the man did not respond and instead fled on foot, clutching and “fiddling” with his pocket as he ran. After a brief pursuit, he surrendered, and officers conducted a pat-down, discovering a handgun in his jacket pocket.Before trial in the Superior Court of the District of Columbia, the defendant moved to suppress the gun, arguing that it was found as a result of an unlawful seizure and search in violation of the Fourth Amendment. The trial court denied the suppression motion, finding that the officers did not seize the defendant until after his flight and that, at that point, they had reasonable articulable suspicion to stop and frisk him based on his behavior, the observed bulge, his flight, and actions during the pursuit. The court then found the defendant guilty of unlawful possession of a firearm and related charges following a stipulated trial.On appeal, the defendant limited his argument to whether the officers had reasonable articulable suspicion to stop and frisk him when he surrendered. The District of Columbia Court of Appeals concluded that, considering the totality of the circumstances—including the recent shooting in the area, the observed bulge consistent with a firearm, the defendant’s apparent panic and evasive behavior, his flight, and his actions while fleeing—officers had reasonable articulable suspicion to justify the stop and frisk. The court affirmed the convictions, finding no Fourth Amendment violation. View "Doby v. United States" on Justia Law

The defendant was arrested on firearm- and ammunition-related charges in September 2023 and ordered held without bond pending trial. Despite being found competent in two separate evaluations, he refused to physically appear in the courtroom for nearly fifteen months, although he did appear at his initial detention hearing. After holding numerous hearings at which the defendant refused to appear, the trial judge developed a plan to ensure the defendant was informed of his rights and had the opportunity to waive his right to be present at trial. The judge, accompanied by counsel, spoke with the defendant in the courthouse sally port, both informing him of his rights and obtaining a recorded waiver. The defendant expressly waived his right to be present, stating his decision was voluntary and uncoerced.The Superior Court of the District of Columbia, faced with defense objections under Superior Court Rule of Criminal Procedure 43 and requests for further competency evaluations or use of force to bring the defendant to court, determined that the defendant’s waiver was valid. The court refused to authorize the use of force, finding it inappropriate given the circumstances. A jury trial proceeded in the defendant’s absence, resulting in convictions for unlawful possession of a firearm (by a felon), possession of an unregistered firearm, and unlawful possession of ammunition. He was sentenced to eighteen months, but released shortly after due to time already served.On appeal, the District of Columbia Court of Appeals held that the defendant’s waiver of his right to be present was knowing, intelligent, and voluntary, and that the requirements of Rule 43 were satisfied under these unique circumstances. The court further held that there was no clear or obvious error in upholding the felon-in-possession conviction under the Second Amendment, given the lack of controlling precedent. The judgment of the Superior Court was affirmed. View "Rogers v. United States" on Justia Law

A group of plaintiffs, represented by the same counsel as earlier litigants, alleged injuries caused by cellphone radiation exposure. Their complaints were nearly identical to those in a previous set of cases involving similar claims. The plaintiffs agreed, through joint stipulations filed in their cases, that the outcome of expert admissibility litigation in the earlier cases would apply to their own. This agreement included being bound by both the substantive ruling on whether expert testimony about general causation was admissible and all procedural rulings leading up to that determination. The stipulations were signed by counsel for both sides, and subsequent court orders stayed the plaintiffs’ cases pending the resolution of expert admissibility in the earlier litigation.The Superior Court of the District of Columbia managed the earlier cases by first resolving whether the plaintiffs had admissible expert testimony on general causation, limiting discovery to that issue. After several hearings and rulings, the court ultimately excluded the plaintiffs’ expert testimony under the Daubert/Rule 702 standard, and granted summary judgment to the defendants because the plaintiffs lacked the necessary expert evidence to support their claims. The Brooks plaintiffs later moved to lift the stays in their cases, arguing for broader discovery and the opportunity to present new expert witnesses, but the court denied this motion.The District of Columbia Court of Appeals reviewed whether the Brooks plaintiffs were bound by their agreements and the trial court’s rulings. The court held that the plaintiffs had agreed—expressly or implicitly—to be bound by both the outcome of the expert admissibility litigation and the procedural rulings in the earlier cases. The court affirmed the Superior Court’s grant of summary judgment to the defendants, holding that the plaintiffs lacked admissible expert testimony required to prove their claims. View "Brooks v. Mitsubishi Electric & Electronics US, Inc." on Justia Law

Meta Platforms, Inc. operates social media platforms Facebook and Instagram. The District of Columbia sued Meta in the Superior Court of the District of Columbia, alleging violations of the Consumer Protection Procedures Act (CPPA). The District claimed Meta engaged in unfair and deceptive practices by developing features that encouraged children to spend excessive time on its platforms and by misrepresenting the safety of its platforms for children. During discovery, Meta produced millions of documents, some of which it later sought to “claw back,” asserting attorney-client privilege over four internal communications among researchers related to youth well-being research.The Superior Court of the District of Columbia reviewed these four documents in camera at the District’s request. The District argued the crime-fraud exception applied, contending the documents showed attorneys advised Meta researchers to remove or alter research evidencing harms to children, to avoid liability during ongoing litigation. The Superior Court found probable cause to believe the communications furthered consumer fraud, thus invoking the crime-fraud exception and ordering Meta to produce the documents. Meta’s motion for reconsideration, which included new declarations disputing the court’s characterization of the documents, was denied. The court declined to consider the new evidence because it was not timely presented.Meta petitioned the District of Columbia Court of Appeals for a writ of mandamus to vacate the discovery orders. The District of Columbia Court of Appeals denied the petition. The court held that Meta had not shown a “clear and indisputable right” to mandamus relief because the record did not clearly and indisputably foreclose the trial court’s finding of probable cause that the crime-fraud exception applied. The denial of mandamus does not preclude Meta from later challenging the trial court’s findings on direct appeal. View "In re Meta Platforms, Inc." on Justia Law

A father was charged with attempted second-degree cruelty to children after his seven-year-old son arrived at school with significant red marks on his upper left arm. The child told school staff that his “dad did it,” and later said it was caused by a “bat.” The incident arose after the child and his sister were caught with money stolen from their father’s dresser. The father argued that he used reasonable parental discipline, specifically “popping” both children with a belt on their bottoms. The mother, who witnessed the event, testified that the father used a belt on the children’s clothed bottoms and that the father grabbed the child’s arm when he tried to squirm away. There was no evidence of swelling, lasting injury, or need for medical attention beyond an ice pack.In the Superior Court of the District of Columbia, the government’s case relied primarily on the testimony of the child’s teacher and the investigating officer, as well as photographs of the marks. The government did not present testimony from the child or other witnesses to the incident. The trial judge was unable to make any finding as to how the marks were inflicted—whether by a belt, a bat, or a forceful grab—but found the father guilty on the grounds that any force leaving such marks was unreasonable, regardless of the disciplinary purpose.On appeal, the District of Columbia Court of Appeals held that the evidence was insufficient to defeat the reasonable parental discipline defense. The court explained that, under District law and precedent, corporal punishment is permitted so long as it is not excessive, and that short-lived marks or bruises do not, by themselves, prove unreasonable discipline. Because the cause of the marks was uncertain, the injuries were not shown to be serious or lasting, and the disciplinary purpose was undisputed, the conviction was reversed. View "Wilson v. United States" on Justia Law

One afternoon, a group of seven individuals, including the appellant, were standing near a breezeway at an apartment complex in Southeast Washington, D.C. Police officers, who were on routine patrol and not responding to any specific report of criminal activity, stopped near the complex and began approaching the group from about 100 feet away. Upon noticing the officers, the appellant and another man immediately fled at a full sprint through the complex. The officers pursued the appellant, who led them on a chase over fences and through yards, ultimately dropping a firearm as he was apprehended. The police recovered the weapon, and the appellant was charged with several firearm-related offenses.The case was first reviewed by the Superior Court of the District of Columbia. At a suppression hearing, the appellant moved to exclude the gun, arguing the officers lacked reasonable suspicion for his seizure. The trial court found that the seizure occurred when an officer grabbed the appellant’s leg as he attempted to scale a second fence. The court concluded that the officers had reasonable articulable suspicion to justify the seizure, relying on the appellant’s immediate flight upon seeing police, the extended and desperate nature of the chase, and testimony that the apartment complex was a high-crime area. The appellant was convicted at a stipulated trial after the suppression motion was denied.On appeal, a panel of the District of Columbia Court of Appeals vacated the convictions, finding an absence of reasonable suspicion. The court then granted en banc rehearing and vacated the panel’s opinion. The en banc District of Columbia Court of Appeals held that, under the totality of the circumstances, the officers had reasonable articulable suspicion to seize the appellant, primarily due to his unprovoked flight upon seeing police, the particularized testimony about crime at the complex, and the desperation evident in his flight. The court affirmed the convictions. View "D.W. v. United States" on Justia Law

Two women were attacked late at night near the U Street Metro station by a group, including a woman with blonde braids and grey leggings. The victims, Walton and Reynolds, confronted the group to stop fighting, which led to the woman with blonde braids initiating an assault. Walton was knocked unconscious and both women were beaten. Afterward, Walton described her attacker to police and later received an Instagram video depicting the incident. Eight months later, Perry was arrested and charged with two counts of simple assault, allegedly as the principal instigator in the group attack. No pre-arrest identification procedures were conducted by law enforcement.At the Superior Court of the District of Columbia, Perry moved to exclude the Instagram video and any in-court identification based on it, arguing insufficient authentication and reliability. The court denied these motions, permitting the government to introduce the video authenticated by Walton’s testimony and allowing Walton’s in-court identification. After viewing the video and hearing testimony, the court found Perry guilty of both assaults. Perry was sentenced to jail and ordered to pay over $6,000 in restitution for Walton’s medical bills and lost wages. Defense counsel initially objected to the restitution amount's documentation, but after reviewing supporting documents, did not contest the amount further.The District of Columbia Court of Appeals reviewed Perry’s challenges to the video’s admission, the identification, and the restitution order. The court held that the Instagram video was properly authenticated by Walton’s firsthand testimony, did not violate the best evidence rule, was not hearsay, and did not implicate the Confrontation Clause. Walton’s in-court identification was deemed reliable under the circumstances. The restitution order was upheld as factually supported and not based on an impermissible uniform policy. The District of Columbia Court of Appeals affirmed Perry’s convictions and restitution order. View "Perry v. United States" on Justia Law