Justia District of Columbia Court of Appeals Opinion Summaries

Douglass Sloan provided a $60,000 short-term loan to Carlos Allen for property rehabilitation, with a 60-day term and a 20% fixed return rate. If unpaid within 60 days, the loan accrued an additional 2% every subsequent 60 days. The loan was subject to the maximum interest rate allowed by D.C. law if not repaid within 60 days. Sloan sought to collect the debt, leading to a dispute over whether the loan's interest rate was usurious, as D.C. law caps interest rates at 24% per annum.The Superior Court of the District of Columbia initially ruled that Allen had waived his usury defense by not raising it for nearly seven years. The court awarded Sloan $256,946.46 plus $97,450 in attorney’s fees and costs. On appeal, the District of Columbia Court of Appeals upheld the attorney’s fees but remanded the case for reconsideration of the usury defense waiver. The trial court then found no substantial prejudice to Sloan from Allen’s delay and ruled the loan usurious, reducing the award to $39,026.46, the remaining principal, plus the affirmed attorney’s fees.The District of Columbia Court of Appeals reviewed the case again. It upheld the trial court’s findings that Allen had not waived his usury defense and that the loan was usurious, as it effectively charged a 34.7% interest rate in its first year. The court rejected Sloan’s arguments against these findings but agreed that Sloan was entitled to post-judgment interest on the award from the date of the initial October 2020 judgment. The court also dismissed Allen’s cross-appeal, which challenged the validity of the loan and the attorney’s fees, as these issues had been resolved in a prior decision. The case was remanded for the imposition of post-judgment interest on the $39,026.46 award. View "Sloan v. Allen" on Justia Law

The case involves a dispute between a condominium unit owners association and certain individual unit owners against the developers of the condominium and the unit owners association of a neighboring condominium. The plaintiffs alleged that the developers violated statutory disclosure requirements and committed fraud by failing to inform them of amendments to the condominium bylaws that imposed restrictions for the benefit of the neighboring condominium. They sought a declaratory judgment that the bylaw amendments were void.The Superior Court of the District of Columbia granted summary judgment in favor of the defendants. The court ruled that the plaintiffs' common law fraud claims were barred by a contractual provision requiring such claims to be asserted within one year of closing. The court also found that the plaintiffs were on constructive notice of the bylaw amendments and failed to demonstrate damages beyond the statutory violation for their claims under the Condominium Act. The court upheld the bylaw amendments, finding they did not violate the Condominium Act and were binding on the plaintiffs.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court's decision. The appellate court held that the one-year contractual limitation period applied to all claims against the developers, including statutory claims under the Condominium Act and the Consumer Protection Procedures Act. The court also found that the bylaw amendments did not violate the Condominium Act, as they were adopted by the declarant when it was the sole unit owner and were necessary to settle litigation with the neighboring condominium. The court concluded that the restrictions in the amended bylaws were reasonable and served a legitimate interest. View "Unit Owners Ass'n of 2337 Champlain St. Condo., et al. v. 2337 Champlain St., LLC, et al." on Justia Law