Justia District of Columbia Court of Appeals Opinion Summaries

Potomac Place Associates, LLC sought to evict Walter Mendez from his apartment following the death of his mother, Teresa Aparicio, with whom he co-signed a lease in 2003. The building was converted into a condominium in 2006 under the Rental Housing Conversion and Sale Act (RHCSA). Ms. Aparicio, being a low-income elderly tenant, was exempt from the requirement to purchase or vacate, allowing her and Mr. Mendez to continue renting. After Ms. Aparicio's death in 2019, Potomac Place issued a notice to Mr. Mendez to either purchase the apartment or vacate, which he refused, leading to the eviction attempt.The Superior Court of the District of Columbia granted summary judgment in favor of Mr. Mendez, rejecting Potomac Place's argument that the exemption applied only during Ms. Aparicio's lifetime. The court found that Mr. Mendez's tenancy was governed by the Rental Housing Act (RHA), which did not provide grounds for his eviction based on the expiration of the lease or the death of a co-tenant.The District of Columbia Court of Appeals reviewed the case de novo, focusing on the statutory interpretation of the RHA and RHCSA. The court held that the RHCSA's protections for low-income elderly and disabled tenants continued post-conversion, and the RHA did not allow for eviction based on the expiration of the lease or the death of a co-tenant. The court affirmed the Superior Court's decision, concluding that Potomac Place could not evict Mr. Mendez under Section 42-3505.01(j) of the RHA, as the conversion process had been completed in 2006, and the RHCSA no longer applied to Mr. Mendez's tenancy. View "Potomac Place Associates, LLC v. Mendez" on Justia Law

Asegedech Kelecha rented a room in her house to Sara Menghesha starting in 2019. On May 1, 2020, Kelecha changed the locks without giving Menghesha a key, leaving her homeless during the COVID-19 pandemic. Menghesha sued Kelecha for unlawful eviction and obtained injunctive relief to regain access to the property. She then won a partial motion for summary judgment on liability for unlawful eviction. At a jury trial on damages, Menghesha was awarded $7,500 in compensatory damages and $75,000 in punitive damages.After the trial, a juror emailed stating disagreement with the decisions made during deliberations. Kelecha filed a motion for a new trial based on this email. The Superior Court initially ordered an evidentiary hearing but later reconsidered and denied the motion, concluding that such an inquiry would impermissibly intrude into the jury’s deliberative process.The District of Columbia Court of Appeals reviewed the case. Kelecha argued that the Superior Court should have held a hearing before denying her new trial motion and that the punitive damages were unsupported by clear and convincing evidence of malice and were unconstitutionally excessive. The Court of Appeals affirmed the Superior Court’s decision, stating that jurors generally cannot impeach their own verdicts under Federal Rule of Evidence 606(b). The court found that any inquiry into the juror’s email would fall under the no-impeachment rule and that no exceptions applied. Additionally, Kelecha’s arguments regarding the sufficiency of evidence for punitive damages and the excessiveness of the award were deemed forfeited because they were not raised in the trial court. Thus, the Court of Appeals upheld the jury’s verdict and the Superior Court’s rulings. View "Kelecha v. Menghesha" on Justia Law

DCA Capitol Hill LTAC, LLC and DCA Capitol Hill SNF, LLC (collectively, “DCA”) leased a property from Capitol Hill Group (“CHG”) in Northeast Washington, DC, to operate a long-term acute care hospital and skilled nursing facility. In 2015, DCA began withholding rent payments, claiming dissatisfaction with CHG’s installation of a new HVAC system and generator. CHG sued for breach of contract, and DCA counterclaimed for declaratory relief, breach of contract, and fraud, alleging misrepresentations by CHG.The Superior Court of the District of Columbia granted summary judgment to CHG on DCA’s fraud counterclaims related to pre-lease representations, citing the lease’s integration clauses. After a bench trial, the court ruled in favor of CHG on its breach-of-contract claim and DCA’s counterclaims, finding that CHG had fulfilled its obligations regarding the HVAC system and generator work. The court also awarded CHG attorneys’ fees based on a provision in the lease.The District of Columbia Court of Appeals affirmed the trial court’s rulings. The appellate court held that DCA’s fraud claims related to pre-lease representations failed as a matter of law because DCA’s reliance on the alleged misrepresentations was unreasonable. The court also concluded that CHG had not breached the lease, as the term “new HVAC system” did not include distribution components, and CHG had fulfilled its generator-related obligations by replacing one generator. The court upheld the trial court’s award of attorneys’ fees to CHG, finding no abuse of discretion.The case was remanded to the trial court to consider whether to award CHG attorneys’ fees associated with the appeal. View "DCA Capitol Hill LTAC, LLC v. Capitol Hill Group" on Justia Law