Justia District of Columbia Court of Appeals Opinion Summaries

The appellant pled guilty to assault with a dangerous weapon and assault with intent to kill while armed, pursuant to a plea agreement under Rule 11(c)(1)(C) which specified a twelve-year sentence. Before sentencing, the appellant moved to withdraw his guilty plea, arguing that one of his attorneys had incorrectly advised him that the judge could reduce the agreed-upon sentence to eight years. Testimony at the motion hearing established that this inaccurate advice was provided, and the trial court credited the attorney who testified to the miscommunication.Following the guilty plea, the Superior Court of the District of Columbia considered the motion to withdraw. The trial court found that although the appellant did not have competent counsel at all times, he failed to show that he would not have taken the plea but for the incorrect advice. The trial court applied the Strickland v. Washington standard, requiring a reasonable probability that the attorney’s deficient performance caused the plea, and denied the motion to withdraw.The District of Columbia Court of Appeals reviewed the trial court’s decision. The appellate court clarified that, under the standard for presentence withdrawal of guilty pleas, a defendant need not show strict Strickland prejudice, especially when the request is made before sentencing. The appellate court held that the trial court erred by requiring such a showing and by not properly weighing the competency of counsel with other relevant factors such as promptness of withdrawal and assertion of legal innocence. The District of Columbia Court of Appeals vacated the trial court’s ruling and remanded the case for reconsideration, instructing the trial court to reassess whether justice demands the withdrawal of the guilty plea based on the correct legal standard. View "Jackson v. United States" on Justia Law

An individual was convicted following a bench trial for unlawful entry after refusing to leave a convenience store when asked to do so by a Metropolitan Police Department officer at the request of a store clerk. The arrest occurred shortly after the discovery of a deceased person in the store’s back room, which led to the defendant expressing frustration that the store had not been closed to customers. The responding officer testified at trial, recounting that the store clerk asked for assistance in removing the defendant, and body-worn camera footage corroborated the clerk’s request and the officer’s repeated instructions for the defendant to leave.The case was originally tried in the Superior Court of the District of Columbia. The defense moved for a judgment of acquittal, arguing that the government failed to prove that a person with authority asked the defendant to leave, that it relied on inadmissible hearsay, and that the defendant did not refuse to leave the premises. The trial court credited the testimony of the police officer and found the defendant guilty of unlawful entry.On appeal, the District of Columbia Court of Appeals reviewed the conviction. The appellant argued that the clerk’s statement was inadmissible hearsay, that the government failed to show lawful authority to request his removal, and that there was insufficient evidence of refusal to leave. The Court of Appeals held that the clerk’s statement was properly admitted as nonhearsay because it was introduced to show its effect on the officer and to explain the officer's actions, not to prove the truth of the matter asserted. The court also found sufficient evidence that the clerk had lawful authority over the premises and that the defendant refused to leave after being repeatedly instructed. The conviction was affirmed. View "Hinton v. United States" on Justia Law

A patient was admitted to a hospital after suffering chest pains and remained hospitalized for three months until his death. During his stay, he developed a severe Stage 4 sacral ulcer. The patient’s widow, acting individually and as personal representative of his estate, filed suit against the hospital and associated medical providers for negligence and medical malpractice, alleging that failures in wound care, skin monitoring, and repositioning caused the ulcer and contributed to his suffering and death. She also asserted a claim for lack of informed consent regarding risks of long-term hospitalization.The case was first reviewed by the Superior Court of the District of Columbia. During proceedings, the plaintiff shifted her theory to res ipsa loquitur, arguing that negligence could be inferred solely from the development of a Stage 4 ulcer during hospitalization. The Superior Court rejected application of res ipsa loquitur, expressing skepticism about the informed consent claim, and granted summary judgment for the defendants. The court also excluded the plaintiff’s expert testimony but gave little explanation for its reasoning.On appeal, the District of Columbia Court of Appeals conducted de novo review and affirmed the Superior Court’s judgment. The appellate court held that the plaintiff failed to establish a triable res ipsa loquitur case because her experts did not sufficiently address the patient’s multiple comorbidities, which were shown by defense evidence to have contributed to the unavoidable development and worsening of the ulcer. The court also held that the lack of informed consent claim failed due to the absence of expert testimony establishing that long-term hospitalization posed distinct risks compared to alternative care, or that the patient had a meaningful choice. Thus, summary judgment for the defendants was affirmed. View "Pearson v. Medstar Washington Hospital Center" on Justia Law

The case concerns a parcel of property located in a network of alleyways in downtown Washington, D.C. The property, formerly owned by a partnership concerned about crime and disruption related to nightclub use, was sold in 2008 subject to a recorded restrictive covenant prohibiting operation of a nightclub or late-night alcohol establishment. The property changed hands again, and in 2023, the current owner and its lessee sought to open a large nightclub there, despite being aware of the covenant. They secured a provisional alcoholic beverage license, which was granted after a regulatory hearing that did not consider the covenant’s enforceability. When neighboring property owners and the original seller filed suit in the Superior Court of the District of Columbia to enforce the covenant, the current property owner and lessee counterclaimed to invalidate it. After discovery and cross-motions for summary judgment, the Superior Court granted summary judgment to the plaintiffs, upholding the covenant, and dismissed the counterclaim. The court found the covenant’s language unambiguous, that the defendants had notice, and that no substantial changes in the property’s character justified disregarding the restriction. A separate motion to intervene by a neighboring property owner, JPMorgan Chase Bank, was denied as moot. On appeal, the District of Columbia Court of Appeals affirmed the Superior Court’s decisions. It held that unambiguous, perpetual restrictive covenants are enforceable unless unreasonable or contrary to public policy, and the circumstances here did not warrant equitable nonenforcement. The court also found that the proposed fact disputes were not material and that the denial of JPMorgan’s intervention was proper due to the outcome. The judgment was affirmed. View "DTLD, LLC v. Power Station Limited Partnership" on Justia Law

After a woman sold drugs to an undercover officer and left in a car driven by the defendant, police arrested the defendant and recovered nearly $700—including prerecorded bills from the drug purchase—and a bag containing thirty-three grams of a white, powder-like substance from his person. Police also found a firearm, a scale, and additional currency in the car. The defendant was indicted on multiple drug and gun charges, including possession with intent to distribute (PWID) cocaine while armed and unlawful possession of a firearm by a felon (FIP). Before trial, the government dismissed several charges, dropped the while armed enhancement, and elected to proceed on attempted PWID cocaine as a lesser included offense. The defense did not object to these changes.During trial in the Superior Court of the District of Columbia, two officers testified that the bag contained a substance consistent with cocaine, but the court sustained defense objections to testimony that the substance was definitively cocaine, as no testing evidence was presented. After the government stated it was resting its case, the defense moved for judgment of acquittal, arguing insufficient proof regarding both the controlled substance and the firearm charge. The trial court permitted the government to reopen its case to admit a stipulation—previously agreed to by the parties—that the defendant had a prior felony conviction and knew of it, curing a deficiency on the FIP charge. The court denied the acquittal motion, finding the evidence sufficient.On appeal, the District of Columbia Court of Appeals held that the trial court did not abuse its discretion in allowing the government to reopen its case to admit the stipulation. The appellate court affirmed the FIP conviction. Regarding the attempted PWID charge, the court concluded that, because the jury convicted the defendant of attempted PWID of an unspecified controlled substance (rather than cocaine specifically), the felony conviction and sentence for attempted PWID cocaine was improper. The appellate court vacated the felony conviction and remanded for entry of a misdemeanor conviction and resentencing. View "Pritchett v United States" on Justia Law

A licensed clinical social worker, designated as a mandatory reporter under District of Columbia law, reported suspected sexual abuse of a minor patient to the Child and Family Services Agency. The child’s father, who was the subject of the report, subsequently filed suit against the reporter and her employer, alleging professional malpractice and emotional distress. The claims arose from both the initial report and the reporter’s testimony in related proceedings.The Superior Court of the District of Columbia reviewed the defendants’ motion for summary judgment, which invoked statutory immunity granted to mandatory reporters for reports made in good faith. The court granted summary judgment on some counts but denied it on others, including the immunity claim. The court reasoned that there was evidence suggesting the reporter’s actions could have been motivated by bias or malice, and thus the question of good faith should be decided by a jury. The defendants appealed the denial of summary judgment on the immunity issue before final judgment.The District of Columbia Court of Appeals considered whether it had interlocutory jurisdiction under the collateral order doctrine to review the Superior Court’s denial of statutory immunity. The appellate court held that the statute provides immunity from liability, not from suit, and such immunity is effectively reviewable after final judgment rather than through an interlocutory appeal. As a result, the court dismissed the appeal for lack of jurisdiction and remanded the case for further proceedings in the trial court, without reaching the merits of the immunity claim. View "Geraci v. Hamilton" on Justia Law

A juvenile, S.M., was alleged to have committed theft and shoplifting. Initially released pending resolution, S.M. repeatedly absconded, leading to her detention to secure her attendance and protect others’ property. After being detained at the Youth Services Center, S.M. was moved to the Youth Shelter House, but following further incidents of insubordination and unauthorized departures, the trial court ordered her returned to the Youth Services Center.The Superior Court of the District of Columbia issued the order changing S.M.’s place of detention from the Youth Shelter House back to the Youth Services Center. S.M. appealed, arguing that such a move to a more restrictive facility required a specific finding that it was necessary for safety or to secure her appearance, as per D.C. Code § 16-2310(a). The District countered that the order was not subject to the emergency interlocutory review provision of D.C. Code § 16-2328 and that the trial court did not need to make such a finding for placement decisions.The District of Columbia Court of Appeals reviewed the case and concluded that (1) it had jurisdiction under Section 16-2328 to review the order, as it was a detention order; (2) a child can challenge both the fact of detention and the specific place of detention on an emergency interlocutory appeal; and (3) the trial court, when deciding the specific place of detention, is not required to find that placement in a particular facility is necessary to protect safety or ensure appearance. Instead, the selection of the place of detention is a discretionary decision guided by statutory goals, including placing children in the least restrictive setting necessary. The court clarified that the statutory detention criteria apply to the decision to detain, not to the specific location of detention. The disposition affirmed the trial court’s order. View "In re S.M." on Justia Law

A law firm leased office space in downtown Washington, D.C. from a commercial landlord. In the spring of 2020, following the onset of the COVID-19 pandemic and in response to orders issued by the Mayor of the District of Columbia, the law firm curtailed most of its in-office operations and directed employees to work remotely. The firm subsequently invoked a rent abatement provision in its lease, arguing that the pandemic and the government’s orders constituted a force majeure event, which resulted in a material interference with its use and enjoyment of the premises due to an alleged interruption of the essential building service of “secure access” or “prompt access” to the building.The law firm filed a breach of contract suit in the Superior Court of the District of Columbia after the landlord denied the rent abatement request. Both parties moved for summary judgment. The Superior Court denied the law firm’s motion and granted summary judgment to the landlord. The court found that the contract was unambiguous, and that there was no interruption of “secure or prompt access” to the premises, as the building remained physically accessible and the landlord did not impede entry. The court also determined that the government’s orders did not amount to a force majeure “taking” as defined by the lease. The law firm appealed.The District of Columbia Court of Appeals affirmed the trial court’s decision. The appellate court held that under the plain meaning of the lease, “secure and prompt access” refers to physical ability to enter the premises, as provided by the landlord, and not to a generalized right to use the premises free from government restrictions. Because the law firm’s access to the building was never impeded by the landlord, the rent abatement provision was not triggered. View "Crowell & Moring, LLP v. Trea 1001 Pennsylvania Avenue Trust" on Justia Law

In this case, the appellant and her son were charged in connection with an assault and shooting that took place in the stairwell of an apartment building in Southeast Washington, D.C. The incident followed a dispute earlier in the evening between the appellant and the victim, Shawn Watts. After being told to leave the apartment, the appellant returned with her son, who was armed. Together, they assaulted Mr. Watts, with the son ultimately shooting him in the leg. The appellant was tried separately from her son and faced several charges, including conspiracy to commit assault with a dangerous weapon, aggravated assault while armed, and possession of a firearm during a crime of violence (PFCV).The Superior Court of the District of Columbia presided over the jury trial. The jury convicted the appellant of conspiracy to commit assault with a dangerous weapon, aggravated assault while armed (including a “while armed” sentencing enhancement), and PFCV, but acquitted her on other counts. She was sentenced to seventy-two months of imprisonment, followed by supervised release. On appeal, she challenged the sufficiency of the evidence for the PFCV conviction and the “while armed” enhancement, and she also raised issues regarding the trial court’s handling of witness testimony and jury instructions.The District of Columbia Court of Appeals reviewed the case. The court concluded that there was insufficient evidence to sustain the appellant’s conviction for PFCV under an aiding-and-abetting theory, as there was no evidence that the victim posed a threat of disarming the gunman, or that the appellant’s actions were undertaken with the requisite guilty knowledge. However, the court found sufficient evidence for the “while armed” enhancement to the aggravated assault conviction, as the appellant knew about the gun and continued to participate in the assault. The court affirmed the convictions for conspiracy and aggravated assault with the enhancement, but reversed the PFCV conviction. View "Chandler v. United States" on Justia Law

A Black man was charged with two counts of first-degree sexual abuse and one count of attempted robbery after allegedly assaulting a white woman. During jury selection, the government used its peremptory strikes to remove all six nonwhite prospective jurors—four Black, one Asian, and one Hispanic—from a venire of thirty-six, resulting in an all-white jury. The defense objected, arguing that the prosecutor’s actions were racially discriminatory and violated the precedent established in Batson v. Kentucky. The government provided purportedly race-neutral reasons for the strikes of the Black jurors, such as concerns about their ability to understand scientific testimony or responses during voir dire. The trial court accepted these explanations, found them credible and race-neutral, and denied the Batson challenge.A jury in the Superior Court of the District of Columbia acquitted the defendant of attempted robbery but convicted him on both sexual abuse counts. On appeal, a division of the District of Columbia Court of Appeals affirmed the convictions, concluding that the trial court had adequately scrutinized the government’s justifications for the jury strikes. The defendant sought en banc review, and the division’s decision was vacated pending review by the full District of Columbia Court of Appeals.The District of Columbia Court of Appeals, sitting en banc, held that the trial court’s Batson analysis was insufficient because it failed to rigorously scrutinize the prosecutor’s explanations in the context of the entire record, including statistical evidence and the racially charged nature of the case. The court found that at least one of the government’s strikes was more likely than not racially discriminatory. Accordingly, it reversed the defendant’s convictions and remanded for a new trial. View "Smith v. United States" on Justia Law