Justia District of Columbia Court of Appeals Opinion Summaries

Christian Greene, the Ombudsman for the District of Columbia Child & Family Services Agency (CFSA), was terminated from her position and subsequently filed a lawsuit against the District, claiming her termination violated the District of Columbia Whistleblower Protection Act (WPA). Greene argued that her termination was in retaliation for her disclosures about CFSA's non-compliance with the Foster Youth Statements of Rights and Responsibilities Amendment Act of 2012 (FYAA).The Superior Court of the District of Columbia granted summary judgment in favor of CFSA, concluding that Greene's disclosures were merely policy disagreements about the role of the Ombudsman and not protected under the WPA. The court did not address whether Greene reasonably believed her disclosures revealed unlawful activity or whether there was a causal connection between her disclosures and her termination.The District of Columbia Court of Appeals reviewed the case and found that Greene's disclosures were indeed protected under the WPA. The court held that Greene reasonably believed her disclosures revealed violations of the FYAA, which required CFSA to report on the outcomes of investigations and ensure compliance with relevant laws. The court noted that Greene's belief was genuine and reasonable, given the evidence she provided and the context of her role.The Court of Appeals reversed the trial court's grant of summary judgment in part and remanded the case for further proceedings. The trial court was instructed to determine whether there is a genuine dispute of material fact regarding whether Greene's WPA-protected disclosures were a cause of her termination. View "Greene v. D.C. Child & Family Services Agency" on Justia Law

Skylar Meinhardt, a former professional soccer player for the Washington Freedom, sustained a left knee injury in 2001 or 2002. Years later, she developed a right knee disability, which she attributed to compensating for her earlier left knee injury. Meinhardt claimed that her altered gait due to the left knee injury led to the deterioration of her right knee, resulting in pain first reported in 2015 and necessitating surgeries in 2016 and 2019.An Administrative Law Judge (ALJ) denied Meinhardt's workers' compensation claim, mistakenly framing the issue as whether a right knee injury in 2002 was related to the left knee injury in 2001. The ALJ found Meinhardt non-credible, partly because of her prior right knee surgeries in 1996, 1999, and 2001, and because the evidence did not support a right knee injury in 2002. The Compensation Review Board (CRB) affirmed the ALJ's decision, also mischaracterizing the issue as whether a 2002 right knee injury was related to the 2001 left knee injury.The District of Columbia Court of Appeals vacated the CRB's order and remanded the case for further proceedings. The court clarified that the central issue was whether Meinhardt's 2015 right knee disability was causally connected to her 2001-2002 left knee injury. The court found that both the ALJ and CRB had misunderstood the claim, leading to an erroneous denial of benefits. The court also noted that the evidence used to rebut the presumption of compensability, particularly a letter from Dr. Clinton Soppe, was not specific and comprehensive enough, as it incorrectly stated that Meinhardt's right knee pain began acutely in 2016.The case was remanded to the CRB, with instructions to remand it further to the ALJ for reconsideration, focusing on whether the 2015 right knee disability was causally related to the 2001-2002 left knee injury. View "Little v. D.C. Dep't of Employment Services" on Justia Law

In 2002, the appellant was convicted of armed robbery and assault with a dangerous weapon. He later filed two motions for post-conviction relief under D.C. Code § 23-110. The first motion, filed in 2017, claimed ineffective assistance of trial counsel and alleged that he was beaten by U.S. Marshals during his trial, rendering him unable to participate meaningfully in his defense. He attached an affidavit and medical records to support his claims. The second motion, filed pro se, argued ineffective assistance of post-conviction counsel during a 2016 sentence reduction hearing.The Superior Court of the District of Columbia denied the first § 23-110 motion after an evidentiary hearing. The court found that the appellant's absence from the hearing meant his affidavit was inadmissible hearsay and that the medical records did not sufficiently demonstrate that he was unable to participate in his trial. The court concluded there was no evidence, aside from the inadmissible affidavit, to support the claim that the appellant was too emotionally or physically impaired to assist in his defense.The appellant's second § 23-110 motion was also denied by the Superior Court. The court found that the appellant had not demonstrated prejudice from his post-conviction counsel's performance during the Rule 35 sentence reduction hearing. The appellant appealed both denials.The District of Columbia Court of Appeals reviewed the case. It affirmed the denial of the first § 23-110 motion, agreeing with the lower court that the appellant's affidavit was inadmissible and that the medical records did not prove his inability to participate in his trial. The court dismissed the appeal of the second § 23-110 motion as moot because the appellant had already completed his term of imprisonment, and his term of supervised release was statutorily unalterable. View "Thompson v. United States" 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

On the evening of September 10, 2018, Metropolitan Police Department officers received a ShotSpotter alert indicating a possible gunshot near their location. Shortly after, they encountered Maurice Mitchell riding a bicycle away from the general area of the alert. The officers testified that Mitchell flinched and increased his speed upon noticing their patrol car. They followed him, activated their emergency lights, and stopped him. Upon approaching Mitchell, they observed a firearm protruding from an open bag on his bicycle. Mitchell was subsequently convicted of multiple firearm-related offenses following a stipulated trial.The Superior Court of the District of Columbia denied Mitchell's motion to suppress the firearm, ruling that the officers had reasonable suspicion to stop him based on his proximity to the ShotSpotter alert, his evasive behavior, and the lateness of the hour. Mitchell was convicted and sentenced to eighteen months of incarceration, suspended as to all but twelve months, followed by supervised release and probation. He appealed the denial of his motion to suppress, arguing that the stop was unlawful due to a lack of particularized and articulable suspicion.The District of Columbia Court of Appeals reviewed the case and concluded that the officers lacked reasonable, articulable suspicion to stop Mitchell. The court found that the factors cited by the trial court, including Mitchell's proximity to the ShotSpotter alert, his attire, and his behavior, were insufficient to justify the stop. The court emphasized that the totality of the circumstances did not provide a particularized and objective basis for suspecting Mitchell of criminal activity. Consequently, the court reversed the trial court's denial of the motion to suppress, vacated Mitchell's convictions, and remanded the case for further proceedings consistent with its opinion. View "Mitchell v. United States" on Justia Law

In this case, four individuals, alleged members of the criminal street gang "G-Rod," were involved in three separate shootings in 2010, resulting in two deaths and two injuries. The defendants, Lester Williams, Robert Givens, Marcellus Jackson, and Keir Johnson, were convicted of various crimes related to these incidents after a four-month jury trial.The Superior Court of the District of Columbia presided over the trial. The court admitted a rap video as evidence, which the defendants argued was inadmissible. The court also allowed lay interpretation of coded conversations and addressed issues related to jury selection, including the government's selective investigation of potential jurors and the use of peremptory challenges. The court denied motions to suppress certain evidence and ruled on the admissibility of cell-site data.The District of Columbia Court of Appeals reviewed the case. The court held that the convictions of Jackson, Johnson, and Williams should be remanded for a Motorola hearing regarding the admissibility of cell-site evidence. The court also concluded that the convictions under D.C. Code § 22-951(b) related to misdemeanor conspiracy could not stand and that certain duplicative convictions must merge. The court vacated Jackson's conviction for second-degree murder due to insufficient evidence and the related street gang conviction. The court found no reversible errors in the other aspects of the trial and affirmed the remaining convictions.The court's main holdings included the need for a remand to apply the Motorola standard to the cell-site evidence, the vacating of certain convictions due to insufficient evidence, and the merging of duplicative convictions. The court also addressed issues related to jury selection and the admissibility of evidence, ultimately affirming most of the convictions while remanding for further proceedings on specific issues. View "Williams, et al. v. United States" on Justia Law

The respondent, a member of the District of Columbia Bar, was indefinitely suspended from practicing law in Maryland by consent. The suspension was contingent on several conditions, including a satisfactory report from a mental health or substance abuse professional addressing the respondent's alcohol and drug issues. Subsequently, the District of Columbia Court of Appeals issued an order suspending the respondent and directing him to show cause why reciprocal discipline should not be imposed. The respondent did not file a response or the required affidavit.The District of Columbia Court of Appeals reviewed the case. The Disciplinary Counsel recommended that the respondent's reinstatement be conditioned on his reinstatement in Maryland and a demonstration of fitness. The court noted that the respondent had not participated in the proceedings and had not filed the necessary affidavit.The District of Columbia Court of Appeals ordered that the respondent be indefinitely suspended from practicing law in the District of Columbia, with a fitness requirement. The respondent must comply with all conditions imposed by Maryland and demonstrate that he has addressed his mental health and substance abuse issues. The respondent may seek reinstatement after five years or after being reinstated by Maryland, whichever occurs first. The suspension will not begin until the respondent files an affidavit that fully complies with the requirements of D.C. Bar R. XI, § 14(g). View "In re Sayadian" on Justia Law

Claudia Allen sued the District of Columbia after being assessed a late payment penalty for a traffic ticket. Allen had timely mailed her payment using a pre-addressed envelope provided by the District, but the post office failed to deliver it, returning it as undeliverable. Allen claimed that the use of red ink on the pre-addressed envelopes caused the delivery failure, as it was difficult for USPS machines to read. She sought damages for negligence and aimed to certify a class of similarly affected individuals.The Superior Court of the District of Columbia granted summary judgment for the District on Allen's individual negligence claim, concluding that the evidence did not support a reasonable jury finding that the red ink caused the delivery failure. The court also denied her request for class certification, determining that she did not meet the Rule 23 requirements for a class action.The District of Columbia Court of Appeals reviewed the case and agreed with the lower court's decision. The court found that Allen's expert, Peter Wade, did not provide sufficient evidence to support the claim that red ink caused the delivery failure. Wade's testimony indicated that the likelihood of an envelope going undelivered was very low regardless of the ink color. The court also noted that Wade ultimately agreed with the District's expert, John Mashia, that the failed delivery was due to USPS error, not the red ink.The Court of Appeals affirmed the grant of summary judgment for the District, concluding that Allen did not present a viable negligence claim. Consequently, the court also affirmed the denial of class certification, as Allen could not represent a class without a valid individual claim. View "Allen v. District of Columbia" on Justia Law