Justia District of Columbia Court of Appeals Opinion Summaries

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

The appellant committed a series of violent crimes in 1982, including first-degree murder, rape, and armed robbery, when he was eighteen years old. He entered into a global plea agreement, receiving a sixty-five years to life sentence. During his forty-three years of incarceration, he took part in a wide range of educational and rehabilitative programs, maintained employment, and generally avoided violent infractions, with only one such infraction in 1999. However, he did receive a disciplinary infraction for “stalking” female prison staff in 2016, which was characterized by repeated grievances and derogatory language rather than physical or sexual misconduct. He was not referred to, nor did he complete, sex offender treatment, though a psychological expert opined this was not necessary for his rehabilitation.After serving the minimum time required, the appellant filed a motion in the Superior Court of the District of Columbia seeking sentence reduction under the Incarceration Reduction Amendment Act (IRAA). At the evidentiary hearing, he presented evidence of his rehabilitation and low risk of recidivism, including a favorable PATTERN score and a psychologist’s report. The trial court denied the motion, finding he failed to prove he was no longer dangerous, placing significant weight on his lack of sex offender treatment and the 2016 infraction, and referencing factors such as the seriousness of his original offenses and deterrence.The District of Columbia Court of Appeals vacated the trial court’s decision and remanded the case. The appellate court held that the trial court abused its discretion by relying on an unsupported assumption that the appellant needed sex offender treatment to demonstrate non-dangerousness, despite expert evidence to the contrary. The appellate court also found error in the trial court’s interests of justice analysis by relying on factors outside those enumerated in the IRAA, including seriousness of the offense. The case was remanded for further proceedings consistent with the appellate opinion. View "Davidson v. United States" on Justia Law

Police officers encountered a man at a playground in a public park while he was with his daughter and partner. The officers were conducting a patrol and had observed a group they suspected of smoking marijuana. The man had walked away from the group to rejoin his family. Five armed, uniformed officers approached and encircled him, with two officers standing within arm's reach and three others positioned nearby. One officer asked if the man had a firearm, and he admitted that he did; officers then frisked him and recovered a gun from his waistband.The Superior Court of the District of Columbia held a hearing on a motion to suppress the firearm. The trial court found that the defendant was not seized until after he admitted to possessing a firearm and officers physically restrained him. The court emphasized the officers’ cordial tone, the brief nature of the encounter, and the public setting, and denied the motion to suppress. The case proceeded to trial, and a jury convicted the defendant of unlawful possession of a firearm, carrying a pistol without a license, and possession of an unregistered firearm.The District of Columbia Court of Appeals reviewed the case. It held that the defendant was seized for Fourth Amendment purposes before he admitted to possessing a firearm—specifically, when five officers encircled and focused exclusively on him, blocking his exits and asking accusatory questions. The court concluded that this seizure was unsupported by reasonable articulable suspicion and thus unlawful. It reversed all convictions, holding that the firearm should have been suppressed as the fruit of the unlawful seizure, and remanded the case for further proceedings. View "Ervin v. United States" on Justia Law

Danielle Pennington was the former owner of a property that was foreclosed and sold in 2019 to the predecessor of First Hand Land, LLC. After the sale, Pennington remained on the property, and First Hand Land subsequently sought to evict her. The Superior Court of the District of Columbia granted First Hand Land a writ of restitution, permitting Pennington’s eviction from the premises. Pennington, representing herself, appealed this order and requested that the District of Columbia Court of Appeals enjoin her eviction pending the appeal, which the court denied. She was evicted the following day.Following her eviction, Pennington moved for reconsideration, presenting what she claimed was a federal district court order granting her quiet title to the property. First Hand Land responded by asserting that the purported federal order was a forgery, pointing out discrepancies such as the absence of the order from the federal court’s docket and inconsistencies with the actual disposition of Pennington’s federal case, which had been dismissed prior to the date on the alleged order. The Superior Court, in a parallel action, also found the order to be fraudulent and noted further irregularities, including mismatched dates and the submission of the forged order to official agencies.The District of Columbia Court of Appeals reviewed the materials and found, based on judicially noticeable facts and uncontested evidence, that Pennington had submitted a forged order. The court adopted a standard allowing dismissal of appeals as a sanction for willful deception and conduct grossly inconsistent with the administration of justice. Applying this standard, it dismissed Pennington’s appeal and pending motions as a sanction for her litigation misconduct, concluding that no lesser sanction would be sufficient. View "Pennington v. First Hand Land, LLC" on Justia Law

David Kaplan brought a lawsuit against MedStar Georgetown Medical Center, Inc. and an affiliated medical group, alleging that they failed to meet the national standard of care in treating his Crohn’s disease and did not obtain his informed consent for treatment. As a result of the alleged medical negligence, Kaplan endured prolonged use of steroids, which did not alleviate his condition and ultimately led to the complete deterioration of his hip bones. He subsequently required three hip replacement surgeries, experiencing significant physical pain, emotional distress, and limitations on his lifestyle and activities.The Superior Court of the District of Columbia presided over a jury trial, where the jury found MedStar liable for both breaching the standard of care and failing to obtain informed consent. The jury awarded Kaplan $4 million in damages, allocating separate amounts for past and future physical injury and for past and future emotional distress. MedStar timely objected to the verdict form, aspects of Kaplan’s closing argument, and the amount of damages, and subsequently filed a post-trial motion seeking judgment as a matter of law or, alternatively, a reduction in damages. The trial court denied these motions.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court’s judgment. The appellate court held that the trial court did not abuse its discretion by allowing the verdict form to separately list damages for physical injury and emotional distress, as these are conceptually distinct forms of harm. The court further found that any improper argument in Kaplan’s closing was adequately addressed by curative instructions, and that the damages award was not so excessive as to shock the conscience or require remittitur. The judgment in favor of Kaplan was affirmed in its entirety. View "Medstar Georgetown Medical Center, Inc. v. Kaplan" on Justia Law

On the night of September 15, 2016, an altercation occurred in Southeast Washington, D.C., during which Andre Becton shot Darnell Peoples in the leg and neck, resulting in Peoples’s death. The incident followed a verbal exchange and physical struggle between the two men, witnessed by Debra Moore. Mr. Becton fled the scene. Police later identified him as the shooter based on eyewitness accounts and a dying declaration by Peoples. Mr. Becton was arrested after police seized his vehicle and, during an interview, he denied involvement despite being informed of the possibility of a self-defense claim. Investigators obtained and searched Mr. Becton’s iPhone after securing a warrant, recovering text messages and other data.Prior to trial, Mr. Becton’s counsel did not move to suppress the cell phone evidence. At trial in the Superior Court of the District of Columbia, the court excluded evidence of Peoples’s prior domestic violence allegations, finding them more prejudicial than probative under the factors outlined in Shepherd v. United States. The jury convicted Mr. Becton of second-degree murder while acquitting him of first-degree murder. While his direct appeal was pending, Mr. Becton filed a motion under D.C. Code § 23-110, asserting ineffective assistance of counsel for failure to move to suppress the cell phone evidence. The trial court found counsel’s performance deficient but concluded there was no prejudice because the cell phone evidence was not central to the government’s case.The District of Columbia Court of Appeals reviewed both the conviction and the denial of the Section 23-110 motion. The court held that the exclusion of the prior domestic violence evidence was not an abuse of discretion, as the trial court properly balanced its probative value and prejudicial effect. The court also held that Mr. Becton failed to show prejudice from counsel’s performance because the outcome would not likely have changed without the cell phone evidence. Accordingly, the convictions and denial of post-conviction relief were affirmed. View "Becton v. United States" on Justia Law

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