Justia District of Columbia Court of Appeals Opinion Summaries

Travon Celey, a former employee of Children’s National Medical Center, was terminated on March 1, 2022, for accumulating six instances of tardiness within a twelve-month period. Celey subsequently applied for unemployment benefits, but a claims examiner from the District of Columbia Department of Employment Services (DOES) disqualified him, citing gross misconduct due to repeated tardiness following warnings.Celey appealed the decision to the Office of Administrative Hearings (OAH). Despite filing the appeal well beyond the fifteen-day deadline, OAH extended the deadline due to good cause and excusable neglect. During the hearing, the Hospital presented evidence and testimony showing that Celey had been warned and suspended for his tardiness, referencing both the independent Attendance Policy and the collective bargaining agreement (CBA) policy. The CBA policy mandated termination after the sixth instance of tardiness, while the independent Attendance Policy allowed for termination only after the eighth instance.The OAH administrative law judge (ALJ) found that the Hospital had issued inconsistent rules, failing to clearly notify Celey of the specific policy that applied to him. The ALJ concluded that Celey did not willfully violate the Hospital’s expectations and was therefore qualified to receive unemployment benefits.The District of Columbia Court of Appeals reviewed the case and affirmed the OAH decision. The court held that substantial evidence supported the ALJ’s finding that Celey was not adequately informed about the CBA policy, which was crucial for determining his eligibility for unemployment benefits. The court emphasized that the issue was whether Celey was on notice that his conduct could lead to termination, not whether the Hospital was justified in terminating him. View "Children's National Medical Center v. Celey" on Justia Law

Desean Hattix was convicted of attempted failure to register a firearm after police executed a search warrant at his home and found two unregistered handguns. Following his conviction, the District of Columbia Housing Authority (DCHA) sought to evict him from his federally subsidized housing unit, alleging that his possession of an unregistered firearm violated the federal "one-strike" provision in his lease, which prohibits tenants from engaging in criminal activity that threatens the health, safety, or peaceful enjoyment of the property. The trial court found that Mr. Hattix's unlawful possession of a firearm violated this provision and issued a nonredeemable judgment against him.The magistrate judge found that Mr. Hattix's possession of an unregistered firearm threatened the safety of other residents and issued a nonredeemable judgment against him. An associate judge of the Superior Court upheld this decision, finding that Mr. Hattix's gun possession posed both a per se and an individualized threat to the health and safety of other residents. The reviewing judge noted that the District's registration requirements were designed to ensure firearms were not in the hands of dangerous and untrained individuals, and by ignoring this law, Mr. Hattix placed the public at risk.The District of Columbia Court of Appeals reviewed the case and disagreed with the lower courts. The court held that possession of an unregistered firearm does not constitute a per se threat to residents' health, safety, or right to peaceful enjoyment of the property. The court also found that DCHA did not present sufficient evidence that Mr. Hattix's conduct posed an individualized threat to residents' health, safety, or right to peaceful enjoyment of the property. Consequently, the judgment of the Superior Court was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Hattix v. District of Columbia Housing Authority" on Justia Law

In 2003, Sarah Ramey underwent a urethral dilation performed by Dr. Edward Dunne, which resulted in severe pain and subsequent debilitating medical conditions. Over the next fourteen years, Ramey sought medical advice from numerous doctors to determine the cause of her ailments. In 2017, Drs. Mario Castellanos and Lee Arnold Dellon linked her symptoms to the 2003 procedure. Ramey filed a lawsuit against Dr. Dunne and Foxhall Urology in 2019.The Superior Court of the District of Columbia held a bifurcated trial to determine if Ramey’s claim was barred by the statute of limitations. The jury found that Ramey failed to file her suit within the three-year statute of limitations. Ramey then filed a motion for judgment as a matter of law or, alternatively, for a new trial, arguing that the trial court erred in its rulings and jury instructions. The trial court denied her motion.The District of Columbia Court of Appeals reviewed the case. The court held that the trial court did not err in denying Ramey’s motion for judgment as a matter of law, as there was sufficient evidence for a reasonable jury to find that Ramey had received medical opinions linking her symptoms to the urethral dilation before 2017. The court also found that Ramey waived her claim regarding the jury instructions by affirmatively agreeing to them during the trial.However, the Court of Appeals held that the trial court erred in not granting a new trial based on the improper invocation of inquiry notice by appellees’ counsel during rebuttal closing arguments. The court found that the trial court’s corrective instruction was insufficient to mitigate the prejudicial impact of the improper argument. Consequently, the case was remanded for a new trial. View "Ramey v. Foxhall Urology, Chartered" on Justia Law

Barbara McNally sued Debbie-Ann Bromfield and her husband Everald Thompson in the Superior Court for multiple claims related to a property dispute. After Thompson filed for bankruptcy, McNally and Thompson reached a settlement agreement, which included dismissing McNally's pending lawsuit. McNally filed a motion for voluntary dismissal with prejudice under Super. Ct. Civ. R. 41(a)(2), which Bromfield opposed, seeking a decision on the merits through her own summary judgment motion. The trial court granted McNally’s motion to dismiss with prejudice and denied Bromfield’s summary judgment motion as moot, reasoning that Bromfield would not suffer any legal detriment from the dismissal.Bromfield appealed, arguing that the trial court abused its discretion in granting McNally’s motion for voluntary dismissal, claiming it caused her legal prejudice. The District of Columbia Court of Appeals reviewed the case. The court noted that Bromfield was not "aggrieved" by the dismissal with prejudice of the claims against her, as she had effectively prevailed in all relevant respects. The court emphasized that it has an independent obligation to ensure its jurisdiction and that Bromfield did not suffer an infringement or denial of legal rights.The court held that Bromfield’s desire for vindication did not constitute a cognizable legal injury and that her potential future claims, such as a malicious prosecution suit, did not provide grounds for appeal. The court concluded that Bromfield had secured an unmitigated victory in the underlying proceedings and dismissed her appeal for lack of jurisdiction. View "Bromfield-Thompson v. McNally" on Justia Law

In the early morning of November 8, 2015, Charmagne Eccles was robbed at gunpoint by two men near the intersection of 55th Street and Eastern Avenue in Northeast D.C. The assailants stole two iPhones and, after a struggle, Eccles managed to gain possession of the shotgun used in the robbery. The robbers fled but returned with a third man, demanding the shotgun back. Eccles flagged down a police vehicle, and the three men fled. Police used an iPhone tracking application to locate Maurice Ricks, who was found with the stolen phones. A perimeter was established, and a K-9 unit found DeAngelo Parker and Delonta Rollerson hiding in a backyard within the perimeter. Eccles identified Parker and Rollerson in a show-up identification.In the Superior Court of the District of Columbia, Parker, Rollerson, and Ricks were charged with armed robbery and related gun possession charges. Ricks was also charged with assault with intent to kill (AWIK). The defendants filed motions to suppress evidence from the stops and identifications, arguing lack of reasonable suspicion and suggestive identification procedures. The trial court denied these motions, finding reasonable suspicion for the stops and reliability in the identifications. Motions to sever the trials were also denied, as the court found no manifest prejudice from a joint trial. During the trial, the court managed witness testimony and jury questions, including a note about the AWIK charge against Ricks, which the court addressed without granting a mistrial.The District of Columbia Court of Appeals reviewed the case and affirmed the trial court's decisions. The court held that the police had reasonable suspicion to stop Parker and Rollerson based on the totality of the circumstances, including their suspicious behavior and the timing and location of the stop. The court also found that the show-up identifications were not unduly suggestive and were reliable. The denial of severance was upheld, as the defendants did not show manifest prejudice. The court also ruled that the trial court did not abuse its discretion in managing witness testimony and responding to the jury's note. View "Parker & Rollerson v. United States" 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

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

Police officers observed three men in a public park known for PCP use and sales. As officers approached, Devon Greenfield walked away, prompting the officers to follow him. They detected a strong smell of PCP, which intensified as they neared Greenfield. When questioned, Greenfield admitted to drinking beer and allowed officers to look inside his backpack, revealing alcohol. The officers then arrested Greenfield and found three vials of liquid PCP in a small zippered case within his bag.Greenfield was charged with possession of an open container of alcohol (POCA) and attempted possession of PCP. He moved to suppress the evidence, arguing the searches were illegal. The Superior Court of the District of Columbia denied the motion, finding the officers had reasonable suspicion to stop Greenfield and that he consented to the initial search. After a bench trial, Greenfield was convicted on both charges.On appeal to the District of Columbia Court of Appeals, Greenfield argued that the trial court erred in denying his motion to suppress, that there was insufficient evidence to prove his intent to possess PCP, and that the trial court improperly allowed the government to introduce the vials as rebuttal evidence. The Court of Appeals held that the officers had probable cause to arrest Greenfield for POCA based on his admission of drinking beer in the park, which justified the search of his bag incident to arrest. The court also found sufficient evidence to support Greenfield's conviction for attempted possession of PCP, given the distinctive smell and packaging of the vials. Lastly, the court ruled that the trial court did not abuse its discretion in admitting the vials as evidence, even if it was technically a reopening of the government's case rather than rebuttal. The Court of Appeals affirmed Greenfield's convictions. View "Greenfield v. United States" 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

In 1997, a sixteen-year-old, referred to as John Doe, fatally shot his ex-girlfriend and her male companion. He was convicted of first-degree murder while armed, second-degree murder while armed, and two counts of possession of a firearm during a crime of violence. He was sentenced to an aggregate term of seventy-five years to life, later corrected to fifty-five years to life. In 2023, Doe filed a motion under the Incarceration Reduction Amendment Act (IRAA) seeking immediate release. The government did not oppose the motion. The trial court found Doe not dangerous and deserving of a sentence reduction but denied immediate release, reducing his sentence by twenty-two years, making him eligible for release in eighteen months.The Superior Court of the District of Columbia held hearings on Doe’s IRAA motion, during which it heard from the parties and the victims' family members. The court found that Doe had met the burden for IRAA relief, determining he was no longer a danger and that the interests of justice warranted a sentence reduction. However, the court proceeded to a "second step" of resentencing, applying an unrelated statute and considering the seriousness of Doe’s offenses, ultimately reducing his sentence but not granting immediate release.The District of Columbia Court of Appeals reviewed the case. The court held that the trial court erred by applying an unrelated statute and considering the seriousness of the offenses as a standalone factor. The IRAA requires the court to consider specific enumerated factors and does not permit a separate resentencing analysis. Despite these errors, the appellate court affirmed the trial court’s order, concluding that the errors did not cause substantial prejudice to Doe and were therefore harmless. View "Doe v. United States" on Justia Law