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

Salvador Rivas purchased a condominium unit with a mortgage loan from Flagstar Bank, secured by a deed of trust. Rivas fell behind on his condo association dues, leading the New Hampshire House Condominium Unit Owners Association (NHH) to foreclose on the unit in 2014. The foreclosure sale terms indicated the unit was sold subject to Flagstar’s first deed of trust of approximately $256,632. Advanced Financial Investments, LLC (AFI) bought the unit for $26,000, despite its tax-assessed value of $237,930. Flagstar later filed for judicial foreclosure, claiming its lien was extinguished by NHH’s foreclosure sale.The Superior Court of the District of Columbia dismissed Flagstar’s judicial foreclosure claim, reasoning that the lien was extinguished by the prior foreclosure sale. The court also dismissed Flagstar’s claims for declaratory relief, breach of fiduciary duty, and unjust enrichment as time-barred, as they were raised for the first time in an amended complaint filed almost four years after the foreclosure sale.The District of Columbia Court of Appeals reviewed the case. The court agreed with Flagstar that its judicial foreclosure claim was improperly dismissed, as rebuttals to affirmative defenses are not subject to any statute of limitations. However, the court affirmed the trial court’s ruling on the alternative ground that appellees were entitled to summary judgment on the judicial foreclosure claim. The court held that the 2014 foreclosure sale was not unconscionable as a matter of law, given the legal uncertainty at the time regarding whether Flagstar’s lien would survive the sale.The court also rejected Flagstar’s remaining arguments, except for the unjust enrichment claim against AFI. The court found that this claim should not have been dismissed as time-barred and could not be resolved on summary judgment. The case was remanded for trial on the unjust enrichment claim against AFI, while the trial court’s judgment was otherwise affirmed. View "Flagstar Bank, FSB v. Advanced Financial Investments, LLC" 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

Ms. Wilson owned a property in the District of Columbia, which she subdivided into three lots: 825, 826, and 827. She sold Lot 826 to Ntaky Management in 2009 and Lot 825 to Ms. Lumbih in 2010. The deed for Lot 826 described it as measuring twenty feet by forty feet, while the deed for Lot 825 described it as thirty-eight feet in length, based on an informal survey by Vyfhuis & Associates. This created a disputed area of eight feet between the properties. Ms. Lumbih installed an HVAC unit and deck in this disputed area. In 2018, Ntaky asked Ms. Lumbih to remove these installations, but she did not comply, leading Ntaky to sue her.The Superior Court of the District of Columbia held a non-jury trial and ruled that Ntaky owned the disputed area and could remove the encroachments at Ms. Lumbih’s expense. The court also denied Ms. Lumbih’s breach-of-contract claim against Ms. Wilson and her claim for implied indemnity, which sought to hold Ms. Wilson responsible for the costs associated with removing the encroachments.The District of Columbia Court of Appeals reviewed the case. The court upheld the trial court’s decision regarding Ntaky’s ownership of the disputed area and the removal of the encroachments. However, it vacated the denial of Ms. Lumbih’s breach-of-contract claim against Ms. Wilson, finding that the trial court did not address whether Ms. Wilson breached her duty to convey a property thirty-eight feet in length. The case was remanded for further proceedings on this issue. The court affirmed the trial court’s denial of Ms. Lumbih’s claim for implied indemnity, as she failed to identify a non-contractual duty of care owed by Ms. Wilson. View "Lumbih v. Wilson" on Justia Law

Sarah Staab purchased a condominium unit at a foreclosure sale conducted by the condominium association to recover unpaid fees. She later challenged two Superior Court orders that ruled the sale of the unit to her was barred by the Federal Foreclosure Bar, 12 U.S.C. § 4617(j)(3), and thus void, and granted summary judgment to Wells Fargo Bank, N.A. on its claims for judicial foreclosure, declaratory judgment, and quiet title. Staab did not contest that the property was encumbered by a deed of trust owned by the Federal Housing Finance Agency (FHFA) and the Federal National Mortgage Association (Fannie Mae) and serviced by Wells Fargo, nor did she dispute the application of the Federal Foreclosure Bar. Instead, she raised three procedural arguments.The Superior Court of the District of Columbia initially ruled in favor of Wells Fargo, determining that the bank's claims were timely, the foreclosure and sale of the property to Staab were void under the Federal Foreclosure Bar, and the condominium association was not an indispensable party. Staab argued that the court applied the incorrect statute of limitations, abused its discretion by allowing Wells Fargo to amend its complaint years after filing, and erred by not joining the condominium association as an indispensable party.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court's judgment. The court held that Wells Fargo's initial action for judicial foreclosure was timely and that the additional facts and arguments raised in the amended complaint were in direct response to Staab's affirmative defense. The court also concluded that any error in granting Wells Fargo leave to amend its complaint was harmless, as the bank could have raised the same arguments at the summary judgment stage. Finally, the court determined that the condominium association was not an essential party under Super. Ct. Civ. R. 19(a)(1), as the court could grant complete relief without its involvement. View "Staab v. Wells Fargo Bank, N.A." on Justia Law

The case involves a dispute over the title of a condominium unit that was foreclosed upon twice by different lien holders. Wonder Twins Holdings, LLC purchased the property at the first foreclosure sale conducted by the condominium association to recover unpaid assessments. Later, 450101 DC Housing Trust purchased the property at a second foreclosure sale conducted by the mortgage lender. The Superior Court granted summary judgment to DC Housing Trust, ruling that the mortgage had been recorded earlier than the Trustee’s Deed received by Wonder Twins.The Superior Court's decision was based on the premise that the mortgage had priority over the condominium association's lien. The court did not consider the super-priority lien created by D.C. Code § 42-1903.13(a)(2), which gives the condominium association a priority lien for the most recent six months of unpaid assessments. The court also noted that the foreclosure sale was advertised as subject to any prior liens, which it interpreted as preserving the mortgage lender's priority.The District of Columbia Court of Appeals reviewed the case and reaffirmed its previous holdings that the most recent six months of unpaid condominium assessments constitute a super-priority lien. This lien, when foreclosed upon, extinguishes any deed of trust, regardless of the terms of the sale. However, the court also recognized that a 2017 amendment to the Condominium Act requires that if a condominium association forecloses on more than the six-month super-priority lien, the first deed of trust must be preserved.The Court of Appeals found that the record did not clarify whether the condominium association foreclosed only on its super-priority lien or on a split lien. Therefore, it reversed the Superior Court's grant of summary judgment and remanded the case for further proceedings to determine the exact nature of the foreclosure and the resulting priority of the liens. View "Wonder Twins Holdings, LLC v. 450101 DC Housing Trust" on Justia Law

In 2021, the appellee purchased a condominium unit at a foreclosure auction and later filed a complaint in the Superior Court of the District of Columbia to quiet title against Jose Strickland. The complaint was amended to include Plus Properties, LLC, and later Plus Properties Trust as defendants. The docket indicated service was directed to Plus Properties Trust, but no affidavit of service was filed. Plus Properties Trust, represented by Kellee Baker, moved to dismiss some claims but did not allege insufficient service of process. The trial court granted partial dismissal, requiring a responsive pleading by October 4, 2022, which Plus Properties Trust failed to file.The trial court entered default against Plus Properties Trust and scheduled an ex parte proof hearing. Despite being served with notice of the hearing and subsequent motions, Plus Properties Trust did not respond. The court granted default judgment, quieting title in the appellee's name and issuing a preliminary injunction against Plus Properties Trust. Plus Properties Trust, with new counsel, filed two Rule 60(b) motions to vacate the default judgment, arguing lack of notice and ineffective service of process. Both motions were denied by the trial court.The District of Columbia Court of Appeals reviewed the case. The court held that Plus Properties Trust failed to preserve its claim of ineffective service of process by not raising it in the trial court. The court also found that Plus Properties Trust had sufficient notice of the default proceedings and the ex parte proof hearing, as evidenced by the certificates of service. The court concluded that the default judgment did not violate due process and affirmed the trial court's orders denying the Rule 60(b) motions. View "Plus Properties Trust v. Molinuevo Then" on Justia Law

Debra Stevenson and Eugene Smith co-own a property for which Stevenson initially took out a loan from Wells Fargo. After defaulting, she refinanced with Fremont Investment & Loan, which paid off the Wells Fargo loan. Stevenson defaulted again and filed for bankruptcy. HSBC Bank, as Fremont's successor, sought to enforce its interest in the property through equitable subrogation, claiming the right to stand in Wells Fargo's position.In bankruptcy court, HSBC was found to be the holder of the note and entitled to equitable subrogation for the amount used to pay off the Wells Fargo loan. The federal district court adopted this decision, and the D.C. Circuit affirmed, holding that HSBC could enforce its interest despite Fremont's knowledge of Smith's co-ownership and refusal to sign the loan documents.The District of Columbia Court of Appeals reviewed the Superior Court's grant of summary judgment to HSBC. The court held that Stevenson and Smith were collaterally estopped from relitigating issues decided in federal court, including HSBC's standing and entitlement to equitable subrogation. The court also rejected their Truth in Lending Act (TILA) rescission argument, as it had been previously litigated and decided against them. The court affirmed the Superior Court's ruling, finding no genuine issues of material fact and that HSBC was entitled to judgment as a matter of law. View "Stevenson v. HSBC Bank USA" on Justia Law

Corey Nelson-White was barred from Rhode Island Row, a mixed-use development in Northeast D.C., which includes two buildings at 2300 and 2350 Washington Place NE. The barring notice directed him to stay off the property and grounds of Rhode Island Row. Officers explained the barring notice to Nelson-White, but did not provide him with a copy. Six days later, Nelson-White was found inside a parking garage attached to one of the Rhode Island Row buildings and was arrested for unlawful entry.The Superior Court of the District of Columbia convicted Nelson-White of unlawful entry, finding that he knew or should have known he was barred from the premises, including the parking garage. The trial court based its decision on the barring notice and the officers' instructions, despite Nelson-White's argument that the garage was not clearly marked as part of Rhode Island Row.The District of Columbia Court of Appeals reviewed the case and found the evidence insufficient to sustain Nelson-White's conviction. The court noted that there was no clear indication that the parking garage was part of the barred premises. The court highlighted the lack of signage or other markers that would inform a reasonable person that the garage was part of Rhode Island Row or 2350 Washington Place. The court concluded that a rational fact-finder could not determine beyond a reasonable doubt that Nelson-White knew or should have known the garage was included in the barring notice.The District of Columbia Court of Appeals reversed Nelson-White's conviction for unlawful entry, holding that the evidence did not support the conclusion that he was aware or should have been aware that the parking garage was part of the premises he was barred from entering. View "Nelson-White v. United States" on Justia Law