Justia District of Columbia Court of Appeals Opinion Summaries

Rubin Delphonso Holman was convicted of robbery, assault with intent to rob (AWIR), and simple assault. The incident occurred on a Metro train where Holman and his friend, Mr. Black, engaged in inappropriate behavior towards Domini Dotson. After Dotson moved to another train car and reported the incident, Holman followed her, threatened her, and attempted to take her phone. When Dotson resisted, Holman assaulted her, and during the altercation, he took her phone. Holman later threw the phone onto the Metro tracks when approached by police.The Superior Court of the District of Columbia convicted Holman of the charges. Holman appealed, arguing that his convictions for simple assault and AWIR should merge with his robbery conviction under the Double Jeopardy Clause. He also contended that there was insufficient evidence to support his robbery conviction.The District of Columbia Court of Appeals reviewed the case. The court agreed with Holman that his convictions for simple assault and AWIR should merge with his robbery conviction, as robbery requires proof of assault, and thus, the lesser offenses are included within the greater offense of robbery. The court also found that there was sufficient evidence to support Holman’s robbery conviction, as a reasonable jury could infer that Holman intended to permanently deprive Dotson of her phone.The Court of Appeals reversed Holman’s convictions for simple assault and AWIR, affirmed his robbery conviction, and remanded the case for entry of a new judgment and commitment order reflecting only the robbery conviction. The court noted that resentencing was unnecessary as the trial court had imposed concurrent sentences. View "Holman v. United States" on Justia Law

G.W. was taken into custody in the District of Columbia on a delinquency matter. Although released in that matter, the trial court ordered his detention under the Interstate Compact for Juveniles (ICJ) to be picked up by Virginia authorities on a different juvenile matter. When Virginia authorities did not take custody, the trial court dismissed the ICJ matter, but the District of Columbia Department of Youth Rehabilitation Services (DYRS) continued to detain G.W., interpreting the ICJ to require detention until all of G.W.'s juvenile matters in the District were resolved or until Virginia took custody or consented to his release.G.W. filed a petition for a writ of habeas corpus, arguing that DYRS had no authority under the ICJ to detain him once Virginia failed to take custody. DYRS opposed the petition, citing ICJ rules and an advisory opinion by the Interstate Commission for Juveniles. The Superior Court of the District of Columbia denied the petition, relying on the advisory opinion that interpreted the ICJ rules to require detention until charges in the holding state were resolved or there was consent from the demanding state.The District of Columbia Court of Appeals reviewed the case. Since the trial court's ruling, the Commission withdrew the advisory opinion, and both the Commission and the District of Columbia conceded that the ICJ rules did not require G.W.'s detention. The Court of Appeals agreed, holding that ICJ Rule 7-103 did not address detention and that ICJ Rule 6-102.2 required detention only until the demanding state returned the juvenile or the time period for doing so expired. Consequently, the Court of Appeals reversed the judgment of the Superior Court. View "In re G.W." on Justia Law

Lauren and John Paul Szymkowicz, who live near Georgetown University, experienced secondhand smoke infiltrating their home from a neighboring property occupied by a Georgetown undergraduate student. The smoke caused health issues and discomfort for the couple. Despite their efforts to address the issue directly with the student and through various university channels, the problem persisted until the student was eventually relocated by the university.The Szymkowiczes filed a lawsuit against Georgetown University in the Superior Court of the District of Columbia, asserting claims of negligence, negligent infliction of emotional distress, public and private nuisance, and breach of contract. They argued that the university had a duty to mitigate the impacts of student behavior on the surrounding neighborhood, as outlined in Georgetown’s campus plan and the Zoning Commission’s order approving that plan. The trial court dismissed the case, ruling that Georgetown owed no duty to the Szymkowiczes and that no contract existed between the university and the couple.The District of Columbia Court of Appeals reviewed the case de novo. The court affirmed the trial court’s decision, holding that Georgetown University did not owe a duty of care to the Szymkowiczes under common law or based on the campus plan and Zoning Commission’s order. The court also found that the university was not in control of the student’s conduct and thus could not be held liable for nuisance. Additionally, the court determined that no enforceable contract existed between Georgetown and the District of Columbia that would allow the Szymkowiczes to sue for breach of contract. Consequently, the court upheld the dismissal of all claims. View "Szymkowicz v. President and Directors of the College of Georgetown University" on Justia Law

Darrell Jones was charged with assault with intent to kill (AWIK) while armed and related counts after repeatedly stabbing his friend, Wayne Pitt. Jones claimed self-defense and argued that his extreme intoxication, from consuming alcohol, marijuana, and PCP, precluded him from forming the specific intent to kill. The trial court precluded Jones from introducing evidence of his PCP use without expert testimony on the drug’s effects. Jones was convicted on all counts and appealed, arguing that the trial court erred in excluding the PCP evidence.The Superior Court of the District of Columbia precluded Jones from presenting evidence of his PCP use, interpreting the case Jackson v. United States to mean that evidence of PCP use requires expert testimony. Jones argued that Jackson was inapplicable because it involved PCP use many hours before the incident, whereas he and Pitt used PCP shortly before the stabbing. The trial court denied Jones’s request to reconsider its ruling, and Jones was convicted by a jury.The District of Columbia Court of Appeals reviewed the case and found that the trial court erred in precluding evidence of Jones’s PCP use. The court held that the evidence was highly relevant to Jones’s intoxication defense and that there was no overriding unfair prejudice to the government. The court clarified that Jackson did not establish a categorical rule requiring expert testimony for PCP use evidence. The court vacated Jones’s AWIK while armed conviction but affirmed his other convictions for aggravated assault and carrying a dangerous weapon. The case was remanded for further proceedings consistent with the opinion. View "Jones v. United States" on Justia Law

Matthew Bare sued his former employer, Rainforest Alliance, Inc., in the Superior Court of the District of Columbia, alleging that the company failed to pay him a redundancy settlement after his position was made redundant due to a reorganization. Bare claimed that he had agreed to resign in exchange for the settlement, which was contingent upon his execution of a release-of-claims agreement. However, after Bare made critical comments about the company, Rainforest Alliance terminated him and refused to pay the settlement, leading to claims of breach of contract and violation of the District of Columbia Wage Payment and Collection Law.The Superior Court dismissed Bare's complaint with prejudice, agreeing with Rainforest Alliance that Bare had failed to allege the occurrence of a condition precedent—specifically, the execution of a release agreement. The court found that without alleging this, Bare could not claim he had earned the redundancy payment under the contract or the wage law. Bare had argued that the issue of the condition precedent was a factual matter for summary judgment or trial and that Rainforest Alliance had waived the condition by not providing a release agreement. He also requested leave to amend his complaint if the motion to dismiss was granted.The District of Columbia Court of Appeals reviewed the case and held that the trial court should have granted Bare's request to amend his complaint. The appellate court found that Bare's request to amend was his first, the case had been pending for a short time, there was no evidence of bad faith or dilatory motives, and there was no prejudice to Rainforest Alliance. The court also determined that Bare's proposed amendment, which would include allegations that Rainforest Alliance waived the condition precedent by not providing a release agreement, was not futile. Consequently, the appellate court reversed the dismissal and remanded the case for further proceedings. View "Bare v. Rainforest Alliance, Inc." on Justia Law

The case involves Ma Shun Bell, who filed a lawsuit against the law firm Friedman, Framme & Thrush (FFT), formerly known as Weinstock, Friedman & Friedman, alleging unfair trade practices and abuse of process. Bell claimed that FFT, representing First Investors Servicing Corporation (FISC), pursued a deficiency debt from her despite knowing it was not lawfully recoverable due to procedural defects in the vehicle repossession process.In the Superior Court of the District of Columbia, Bell's second amended complaint was dismissed. The court ruled that the complaint failed to allege the elements of a Uniform Commercial Code (UCC) violation, that FFT was immune from suit under the Consumer Protection Procedures Act (CPPA) and the D.C. Automobile Financing and Repossession Act (AFRA) due to its role as litigation attorneys, and that the complaint did not articulate how FFT’s conduct violated the Debt Collection Law (DCL). Additionally, the court found that Bell’s claims were barred by res judicata based on a Small Claims Court judgment in favor of FISC, with which FFT was found to be in privity.The District of Columbia Court of Appeals reviewed the case. The court concluded that Bell’s DCL cause of action could proceed, but her other causes of action were properly dismissed. The court held that the Superior Court erred in finding privity between FFT and FISC solely based on their attorney-client relationship and a contingency-fee arrangement. The court determined that the DCL claims were not barred by res judicata or collateral estoppel and that Bell had sufficiently alleged that FFT misrepresented the amount of the debt and charged excessive fees. The court affirmed the dismissal of the UCC, CPPA, and abuse of process claims but reversed the dismissal of the DCL claim, remanding the case for further proceedings. View "Bell v. Weinstock, Friedman & Friedman, PA" on Justia Law

A public interest law firm, TPM, requested certain budget-request documents from the Mayor of the District of Columbia under the D.C. Freedom of Information Act (D.C. FOIA). TPM sought documents related to the budget requests of the D.C. Public Schools (DCPS) and the Office of the State Superintendent of Education (OSSE) for fiscal year 2019, as well as other related documents. The Mayor refused to produce the draft submissions, claiming they were protected by executive privilege. TPM then filed a complaint in the Superior Court of the District of Columbia seeking the documents and their online publication.The Superior Court denied the Mayor's motion to dismiss and granted TPM's motion for summary judgment. The court ordered the Mayor to produce the requested documents and to comply with the publication requirements of D.C. Code § 2-536. The Mayor appealed, arguing that the documents were protected by executive privilege and that TPM lacked standing to enforce the publication provision.The District of Columbia Court of Appeals reviewed the case. The court rejected the Mayor's claim of executive privilege, stating that the budgetary process involves overlapping responsibilities between the Mayor and the Council, and thus does not fall under the exclusive purview of the executive branch. The court also found that TPM had standing to seek enforcement of the publication provision, as the failure to disclose the documents caused a concrete and particularized injury to TPM.The court affirmed the Superior Court's order requiring the production and online publication of the requested budget documents for fiscal years 2019 to the present. However, it vacated and remanded the portion of the order requiring the publication of other documents under D.C. Code § 2-536, instructing the lower court to clarify the scope of the required publication. View "District of Columbia v. Terris, Pravlik & Millian, LLP" on Justia Law

A woman from North Carolina was found raped and murdered in a Washington, D.C. apartment in March 2017. The victim’s body was discovered bound and stabbed, with evidence of sexual assault. Surveillance footage and ATM records showed her car and credit cards being used in the days following her death. The investigation led to the arrest of El Hadji A. Toure, whose DNA was found at the crime scene and on items used to bind the victim. Video evidence placed Toure near the victim’s apartment shortly before the crime, and he was later seen using her credit and debit cards, always entering the correct PIN. After the murder, Toure’s financial situation improved markedly, as he paid cash for a hotel stay and a car.A jury in the Superior Court of the District of Columbia convicted Toure of multiple offenses, including first-degree murder, sexual abuse, kidnapping, and related charges. He was sentenced to life without release. While his appeal was pending, Toure moved for a new trial, arguing that the government failed to timely disclose disciplinary records (QCARs) for forensic witnesses, in violation of Brady v. Maryland. The Superior Court denied the motion, finding that, even assuming suppression of favorable evidence, there was no reasonable probability the outcome would have been different given the strength of the other evidence.The District of Columbia Court of Appeals reviewed both the convictions and the denial of a new trial. The court held that, although the government failed to timely disclose impeachment evidence, the suppressed material was not material under Brady because the remaining evidence against Toure was overwhelming. The court also found that the prosecutor’s conduct in eliciting certain testimony violated Toure’s confrontation and due process rights, but concluded that any error was harmless beyond a reasonable doubt. The convictions and denial of a new trial were affirmed, with a remand for merger and resentencing as necessary. View "Toure v. United States" on Justia Law

A shelter providing housing to individuals experiencing homelessness terminated a client's services on an emergency basis, alleging that the client posed an imminent threat to the health or safety of others. The client, who had previously been removed from the shelter without proper notice, returned to the shelter and was involved in a confrontation with security officers. The shelter claimed the client was hostile, pushed a security officer, and made threats. The client challenged the termination, leading to an evidentiary hearing.The Office of Administrative Hearings (OAH) reviewed the case. The administrative law judge (ALJ) found that the shelter had previously attempted to terminate the client without proper notice and that the client was within his rights to be at the shelter at the time of the incident. The ALJ determined that the security officers escalated the situation by provoking the client, who only pushed the officer after being provoked. The ALJ did not credit the shelter's witness's testimony that the client made threats, finding it uncorroborated and inconsistent with video evidence.The District of Columbia Court of Appeals reviewed the case. The court upheld the ALJ's decision, agreeing that the ALJ correctly applied the law and that the client's actions were not severe enough to warrant emergency termination under the Homeless Services Reform Act. The court found that the ALJ's credibility determinations were supported by substantial evidence and that the shelter's arguments regarding the client's prior misconduct were unpreserved for appeal. The court affirmed the OAH's order, rejecting the shelter's arguments. View "Catholic Charities--801 East Men's Shelter v. Byrd" on Justia Law

Dominique Robison, a bus operator for the Washington Metropolitan Area Transit Authority (WMATA), was suspended from her job after bringing her own bottle of urine to a scheduled drug test, which was deemed an automatic failure under WMATA’s policy. She was suspended without pay for 180 days and subsequently filed for unemployment benefits, which were initially granted by the claims examiner due to WMATA's failure to provide evidence of misconduct.WMATA appealed to the Office of Administrative Hearings (OAH), where an administrative law judge (ALJ) found that Robison had committed simple misconduct, not gross misconduct, and was disqualified from benefits for the first eight weeks of her unemployment. The ALJ reasoned that Robison’s violation was her first drug-related offense and that WMATA’s decision to suspend rather than terminate her undercut the severity of the offense. The ALJ did not consider WMATA’s argument that Robison was ineligible for benefits because she was merely suspended, not terminated.WMATA then appealed to the District of Columbia Court of Appeals. The court reviewed whether the ALJ made findings of fact on each materially contested issue, whether substantial evidence supported each finding, and whether the ALJ’s conclusions flowed rationally from its findings. The court concluded that Robison’s actions did not rise to the level of gross misconduct, as there was no direct evidence of drug use or impairment, no demonstrable impact on passenger safety or WMATA’s operations, and it was her first offense. The court also determined that Robison was "unemployed" within the meaning of the statute because she was suspended without pay and did not work during the suspension period.The District of Columbia Court of Appeals affirmed the ALJ’s decision. View "WMATA v. Robison" on Justia Law