Justia District of Columbia Court of Appeals Opinion Summaries

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

Leroy Williams, a special police officer with the D.C. Department of General Services (DGS), was terminated in August 2019 for conduct related to unauthorized traffic stops. He was given three options to appeal: filing an appeal with the Office of Employee Appeals, having his union (Fraternal Order of Police, FOP) file a grievance, or filing a grievance personally. Williams chose the second option, and FOP filed a grievance on his behalf. When the grievance could not be settled, it was advanced to arbitration, where the arbitrator upheld Williams's termination.FOP then sought review from the Public Employee Relations Board (PERB), which upheld the arbitrator's decision. FOP subsequently petitioned the Superior Court of the District of Columbia for review, which affirmed PERB's decision. After FOP's counsel withdrew, Williams filed an appeal to the District of Columbia Court of Appeals on his own.The District of Columbia Court of Appeals reviewed whether Williams had standing to bring the appeal. The court noted that the collective bargaining agreement granted the union the sole authority to arbitrate grievances and, consequently, the sole authority to appeal arbitration decisions. The court found that Williams lacked standing to appeal because only the union could pursue such an appeal unless the union breached its duty of fair representation, which was not argued in this case.The court dismissed Williams's appeal for lack of standing, concluding that he could not independently challenge the arbitration award under the terms of the collective bargaining agreement. View "Williams v. Department of General Services" on Justia Law

CorpCar Services Houston, Ltd. (CorpCar) entered into a franchise license agreement with Carey Licensing, Inc., and Carey International, Inc. (collectively Carey) to operate a chauffeur-driven service under the Carey brand in Houston, Texas. In 2015, CorpCar was found liable for punitive damages for creating a racially hostile work environment, which led Carey to terminate the franchise agreement in 2016. CorpCar argued that the termination was wrongful because it did not materially breach the agreement and, even if it had, Carey did not provide an opportunity to cure the violation as required by the agreement.The Superior Court of the District of Columbia granted summary judgment to Carey, finding that CorpCar’s breach was incurable as a matter of law and that CorpCar had an opportunity to cure but failed to do so. The court also denied CorpCar’s cross-motion for summary judgment, concluding that issues of material fact remained for the jury to decide.The District of Columbia Court of Appeals reviewed the case and agreed with the lower court that CorpCar’s breach was material. However, the appellate court disagreed with the finding that the breach was incurable as a matter of law. The court held that the language of the franchise agreement was clear and precluded the application of the incurable breach doctrine. The court also found that there was a dispute of material fact as to whether Carey repudiated the franchise agreement, effectively denying CorpCar an opportunity to cure.The appellate court reversed the grant of summary judgment to Carey and remanded the case for further proceedings. The court instructed that a jury must decide whether Carey repudiated the agreement, whether CorpCar had cured or could have cured its breach, and whether affording an opportunity to cure would have been futile. The denial of CorpCar’s cross-motion for summary judgment was affirmed. View "CorpCar Services Houston, LTD v. Carey Licensing, Inc." on Justia Law

Appellant Yvonne Gant sued The Lynne Experience LTD (TLE) and Giant Foods, LLC (Giant) for negligence after allegedly being struck and injured by a golf cart operated by a TLE employee. Gant claimed that TLE and Giant failed to properly train and supervise their employees, leading to her injuries. TLE moved to dismiss the case, arguing that the District of Columbia’s Workers’ Compensation Act (WCA) provided Gant’s exclusive remedy, thus removing the court’s jurisdiction over the matter. The Superior Court agreed, dismissing Gant’s claims against TLE with prejudice, and later granted summary judgment in favor of Giant, finding no employer-employee relationship that could support Gant’s negligence claim.The Superior Court determined that the WCA provided Gant’s exclusive remedy and that the District of Columbia Department of Employee Services (DOES) had primary jurisdiction over her claims. The court dismissed Gant’s claims against TLE with prejudice, reasoning that any claim under the WCA would be time-barred. Subsequently, the court granted summary judgment for Giant, based on undisputed evidence that Giant was merely a sponsor of the event and had no role in managing or supervising the staff involved.On appeal, Gant argued that TLE failed to secure payment of compensation as required by the WCA and that she should be allowed to maintain her civil action. Alternatively, she requested a stay to present her claim to DOES. The District of Columbia Court of Appeals agreed that the WCA appeared to provide Gant’s exclusive remedy but held that the Superior Court should have dismissed her claim without prejudice. The court affirmed the summary judgment in favor of Giant, noting that Gant failed to present any arguments against it on appeal.The main holding by the District of Columbia Court of Appeals was that the Superior Court should have dismissed Gant’s claim against TLE without prejudice, allowing her the opportunity to pursue her claim with DOES. The court affirmed the summary judgment for Giant, as there was no evidence to support an employer-employee relationship necessary for Gant’s negligence claim. View "Gant v. The Lynne Experience, LTD" on Justia Law

Sylvester Toyer was arrested by Metropolitan Police Department officers after a Washington Area Law Enforcement System (WALES) check revealed an outstanding warrant for his arrest. During a search incident to his arrest, officers found $1,500 in cash and fourteen baggies of crack cocaine on him. Toyer was subsequently charged and convicted of possession with intent to distribute cocaine. He appealed the conviction, challenging the denial of his motion to suppress the evidence, the admission of his bank records, and the sufficiency of the evidence supporting his conviction.The Superior Court of the District of Columbia denied Toyer's motion to suppress the cash and drugs, ruling that the WALES check was lawful and the subsequent search incident to arrest was valid. The court also admitted bank records showing Toyer's monthly social security deposits and withdrawals, which the government argued were relevant to his financial status and potential drug dealing activities. Toyer contended that the records were irrelevant and prejudicial, but the court allowed their admission, finding them probative.The District of Columbia Court of Appeals reviewed the case and upheld the lower court's decisions. The appellate court found that the WALES check did not require reasonable suspicion or probable cause and that the arrest warrant provided sufficient grounds for the search. The court also determined that the bank records were relevant and not unfairly prejudicial, as they provided context for Toyer's financial situation. Finally, the court concluded that the evidence presented at trial, including expert testimony on drug distribution, was sufficient for a reasonable jury to find Toyer guilty beyond a reasonable doubt of possession with intent to distribute cocaine.The Court of Appeals affirmed Toyer's conviction, holding that the trial court did not err in its rulings and that the evidence supported the jury's verdict. View "Toyer v. United States" on Justia Law

The case involves Amaka Oji and Oji Fit World, LLC (OFW), who were approved as Medicaid providers by the D.C. Department of Health Care Finance (DHCF) in 2011. Between 2012 and 2015, they submitted over 24,000 claims for reimbursement for wellness services provided to Medicaid beneficiaries. Investigations by DHCF, the Office of the Inspector General for the Centers for Medicare and Medicaid Services, and the FBI revealed that Oji and OFW regularly overbilled Medicaid, often charging for a full hour of service regardless of the actual time spent or whether the service was provided at all.The District of Columbia filed a lawsuit in April 2021 under the D.C. False Claims Act and the common law doctrine of unjust enrichment. The Superior Court of the District of Columbia granted summary judgment in favor of the District, finding that Oji and OFW had submitted false claims and falsified records. The court awarded the District $1,001,362.50 in treble damages and $497,000 in civil penalties. Oji and OFW's various procedural defenses, including claims of laches and statute of limitations, were deemed waived due to their failure to raise them in a timely manner.The District of Columbia Court of Appeals reviewed the case and affirmed the summary judgment order. However, the court remanded the case for further consideration of the damages and penalties. The appellate court found that the Superior Court had not provided sufficient explanation or analysis for the awarded amounts, making it difficult to review the decision. The appellate court emphasized the need for the trial court to explain its reasoning in detail to permit adequate appellate review. View "Oji Fit World, LLC v. District of Columbia" on Justia Law

The case involves a custody dispute over a seven-year-old child, S.M. Initially, S.M. lived with his mother, Erica Ward, for the first eleven months of his life. He then moved in with his father, Samuel Mack, for the next two-and-a-half years. It is alleged that Mack killed Ward in S.M.’s presence. Following Ward’s death and Mack’s arrest, S.M. stayed with his maternal uncle, Gregory Bowlding, for eight days before moving in with Mack’s adult daughter and S.M.’s half-sister, Samaya. Bowlding sought third-party custody of S.M., despite not being S.M.’s parent or de facto parent.The Superior Court of the District of Columbia dismissed Bowlding’s suit for lack of statutory standing, concluding that he did not meet any of the statutory categories under which third parties are permitted to petition for custody of a minor. The court also rejected Bowlding’s argument that he had standing to seek custody through the court’s common law or equitable powers.The District of Columbia Court of Appeals reviewed the case. Bowlding argued that he had statutory standing under D.C. Code § 16-831.02(a)(1)(C), which allows a third party to seek custody if they are living with the child and exceptional circumstances exist to prevent harm to the child. He acknowledged that he was not living with S.M. at the time he filed his suit but argued for a broad interpretation of the statute. The court disagreed, holding that the plain text of the statute requires the third party to be living with the child at the time of filing. The court also rejected Bowlding’s argument that he had standing under the court’s common law or equitable jurisdiction, noting that the legislative history of the statute did not support such an interpretation. The court affirmed the trial court’s dismissal of Bowlding’s suit for lack of standing. View "Bowlding v. Mack" on Justia Law

In 1993, the appellant was convicted in Wisconsin of third-degree sexual assault and was required to register as a sex offender for fifteen years. After relocating to the District of Columbia, the Court Services and Offender Supervision Agency (CSOSA) notified him in 2019 that he must register as a sex offender for life under the District of Columbia Sex Offender Registration Act (SORA). The appellant filed a motion in Superior Court challenging this determination, arguing that his Wisconsin conviction was not substantially similar to any lifetime-registration offense under SORA.The Superior Court initially scheduled a hearing beyond the statutory sixty-day deadline set by SORA. At the hearing, the appellant contended that the United States had not proven that his Wisconsin conviction involved conduct substantially similar to first-degree or second-degree sexual abuse in the District, which require lifetime registration. The court granted the United States a continuance to obtain additional records from Wisconsin, over the appellant's objection. The additional evidence included transcripts from the preliminary hearing and sentencing, which detailed the appellant's use of force during the assault. The trial court found that the United States had proven by a preponderance of the evidence that the appellant's conduct involved the use of force, thus requiring lifetime registration.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court's decision. The appellate court held that the trial court acted within its discretion in granting the continuance and that the failure to meet SORA's sixty-day deadline did not warrant reversal. The court also found that the evidence was sufficient to support the trial court's finding that the appellant's Wisconsin offense involved the use of force, justifying the lifetime registration requirement. View "Cox v. United States" on Justia Law

Dagoberto Machado was convicted by a jury of multiple offenses related to the inappropriate touching of I.A., his girlfriend’s young niece. The incidents allegedly occurred during the summers of 2016 and 2017 when I.A. was staying with Machado and his girlfriend. I.A. testified that Machado touched her inappropriately on several occasions, including at a public pool and in their home. She did not immediately report the incidents due to uncertainty and fear of affecting family relationships. The government introduced expert testimony from Dr. Stephanie Wolf, a child psychologist, to provide context for I.A.'s delayed reporting, including cultural barriers within Latino communities.The Superior Court of the District of Columbia admitted Dr. Wolf’s testimony over Machado’s objections. Machado argued that Dr. Wolf’s statements about “machismo” in Latino culture were prejudicial. The trial court qualified Dr. Wolf as an expert and allowed her to testify about cultural norms that might impede a child from disclosing abuse. Dr. Wolf mentioned that in Latino culture, men might have a higher standing, which could impact how sexuality and abuse are viewed. The jury found Machado guilty on all counts.The District of Columbia Court of Appeals reviewed the case and found that the trial court erred in admitting Dr. Wolf’s testimony about Latino culture. The court held that the testimony had minimal probative value and was substantially outweighed by its potential to unfairly prejudice the jury against Machado based on ethnic stereotypes. The court emphasized that such testimony could lead the jury to view Machado as more likely to have committed the abuse simply because of his ethnicity. Consequently, the court reversed Machado’s convictions and remanded the case for further proceedings. View "Machado v. United States" 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