Justia District of Columbia Court of Appeals Opinion Summaries

The dispute arose when a homeowner contracted with a tree nursery company to purchase and install six trees on her property in Washington, D.C. The homeowner sought to restore privacy lost when a neighbor removed existing trees, and she wanted the new trees to provide “evergreen screening.” After installation, she was dissatisfied with the results, noting that the trees did not achieve the desired screening effect and that two of the trees died within a year. She refused to pay the remaining contract balance, prompting the nursery to sue for breach of contract. The homeowner counterclaimed, alleging breach of contract, breach of the duty of good faith and fair dealing, breach of the implied warranty of merchantability, and violations of the D.C. Consumer Protection Procedures Act (CPPA).The Superior Court of the District of Columbia held a bench trial. The court found that the contract required the nursery only to select, install, and monitor six trees for six weeks, not to guarantee any particular screening effect. The court ruled in favor of the nursery on its contract claim and on most of the homeowner’s counterclaims, except for a finding that the nursery breached the implied warranty of merchantability as to one tree (the dogwood) that died soon after installation. The court rejected the homeowner’s claims regarding the CPPA and the duty of good faith and fair dealing, and denied her motion for reconsideration.On appeal, the District of Columbia Court of Appeals affirmed the trial court’s judgment on all grounds. The appellate court held that the contract did not obligate the nursery to provide evergreen screening, that the nursery fulfilled its contractual duties, and that the homeowner breached the contract by withholding payment. The court also affirmed the trial court’s application of the clear-and-convincing-evidence standard to the intentional CPPA claims and agreed that the implied warranty of merchantability was breached only as to the one tree that died. View "Galvin v. Ruppert Nurseries, Inc." on Justia Law

The case concerns an incident in which the appellant shot his longtime friend during an argument over a small debt. The altercation escalated when the appellant, sitting in his car, pointed a gun at the friend and fired three shots, injuring him. The friend fled, and the appellant left the scene, later crashing his car. Police identified and arrested the appellant about six weeks after the shooting. He was indicted for assault with intent to kill and related firearm offenses.During pretrial proceedings in the Superior Court of the District of Columbia, the appellant notified the court and the government of his intent to raise an insanity defense. He provided notice that his expert, Dr. Lally, would testify that the appellant met the legal standard for insanity, basing his opinion largely on a report by Dr. Grant, which detailed the appellant’s history of severe mental illness and hospitalizations but did not reach a definitive conclusion on insanity. The government argued that the expert notice was insufficient under Rule 16 and moved to preclude Dr. Lally’s testimony. The trial court agreed, finding the notice deficient and, without allowing the appellant an opportunity to cure the issue, barred Dr. Lally from testifying. As a result, the appellant abandoned his insanity defense. The trial proceeded on the issue of guilt, and the jury convicted the appellant of aggravated assault while armed and related offenses, acquitting him of the most serious charge.On appeal, the District of Columbia Court of Appeals held that the appellant’s expert notice satisfied the requirements of Rule 16 as it existed at the time. The court further found that, even if there had been a deficiency, the trial court’s sanction of precluding the expert was disproportionate and an abuse of discretion, especially since the appellant was not given a chance to cure any perceived defect. The court provisionally vacated the convictions and remanded for a new trial limited to the insanity defense. If the jury finds the appellant not guilty by reason of insanity, the convictions remain vacated; otherwise, the convictions may be reinstated. The court also found no reversible error in the trial court’s handling of the self-defense instruction. View "Farmer v. United States" on Justia Law

A law enforcement agency in the District of Columbia, responsible for supervising individuals on supervised release, imposed GPS monitoring on a supervisee without judicial or Parole Commission authorization. The agency’s internal regulations permitted its officers to unilaterally require GPS monitoring as an administrative sanction, and this practice had been applied to thousands of supervisees over two decades. In this instance, the supervisee was placed on GPS monitoring twice, first for a positive drug test and then for submitting questionable urine samples. Subsequently, police investigating an armed robbery used the agency’s GPS data to identify and locate the supervisee, leading to his arrest and the recovery of stolen property and a firearm.The Superior Court of the District of Columbia reviewed the supervisee’s motion to suppress the GPS evidence and its fruits, following the District of Columbia Court of Appeals’ recent decision in Davis v. United States, 306 A.3d 89 (D.C. 2023), which held that the agency lacked statutory authority to impose GPS monitoring absent judicial or Parole Commission approval, rendering such searches unconstitutional. The government conceded the constitutional violation but argued that the good faith exception to the exclusionary rule should apply, as the agency reasonably relied on its own regulations. The trial court rejected this argument and granted the suppression motion.On appeal, the District of Columbia Court of Appeals affirmed the trial court’s ruling. The court held that the exclusionary rule applies because the agency is a law enforcement entity, not a neutral third party like a judge or legislature, and thus should feel the deterrent effect of suppression. The good faith exception does not apply when a law enforcement agency unilaterally authorizes unconstitutional searches based on its own mistaken interpretation of its authority. The court concluded that suppression is warranted to deter systemic constitutional violations. View "United States v. Wells" on Justia Law

In this case, the appellant purchased a car through an installment sales contract, which was later assigned to a finance company. After the appellant defaulted on payments, the finance company repossessed the vehicle and, through its attorneys, filed a claim in Small Claims Court to recover a deficiency balance. The appellant, representing herself, entered into a settlement agreement to pay the claimed amount in installments. After defaulting on the settlement, a judgment was entered against her, which was satisfied through wage garnishment. Subsequently, the appellant, now represented by counsel, filed a putative class action against the law firm that represented the finance company, alleging violations of various consumer protection laws and abuse of process, based on the assertion that the deficiency debt was not lawfully recoverable due to procedural defects in the repossession process.Previously, the District of Columbia Superior Court dismissed the appellant’s complaint, finding that the law firm was in privity with the finance company for res judicata purposes, and that the complaint failed to state claims under the Uniform Commercial Code (UCC), the District’s Automobile Financing and Repossession Act (AFRA), the Consumer Protection Procedures Act (CPPA), the Debt Collection Law (DCL), and for abuse of process. On an earlier appeal, the District of Columbia Court of Appeals held that the attorney-client relationship alone did not establish privity for res judicata and remanded for further analysis of the mutuality of legal interests.On review, the District of Columbia Court of Appeals held that the appellant’s DCL claim against the law firm could proceed, as the complaint plausibly alleged that the law firm willfully used deceptive means to collect a debt that was not lawfully owed, including seeking to recover an excessive retaking fee and pursuing a deficiency despite procedural defects. The court found that the law firm and finance company did not have the same legal interest in the subject matter of the prior Small Claims action, so res judicata did not bar the DCL claim. However, the court affirmed dismissal of the claims under AFRA, the UCC, the CPPA, and for abuse of process, finding the complaint insufficient as to those causes of action. The case was remanded for further proceedings on the DCL claim only. View "Bell v. Weinstock, Friedman & Friedman, PA" on Justia Law

In 1999, a twenty-year-old man was involved in a fatal shooting outside a nightclub after his friend was violently attacked by a group. He fired several shots into the crowd, resulting in the death of one of the attackers. He was indicted for first-degree murder and related weapons offenses. After a mistrial, a second jury acquitted him of first-degree murder but convicted him of second-degree murder and two firearm offenses. He was sentenced to twenty-one years to life in prison, and his convictions were affirmed on direct appeal.More than two decades later, he sought a sentence reduction under the Incarceration Reduction Amendment Act (IRAA), arguing that he had matured and was no longer a danger. The Superior Court of the District of Columbia denied his motion, finding he had not shown non-dangerousness or that the interests of justice warranted a reduction. The court weighed heavily his teenage criminal history, prison infractions, and concluded he had a stable, abuse-free childhood, and that no one else was involved in the offense.The District of Columbia Court of Appeals reviewed the denial for abuse of discretion. The court found three significant errors: the trial court failed to consider the mitigating role of third-party attackers in the offense; it incorrectly found the applicant had not experienced childhood sexual abuse, despite clear evidence; and it gave excessive weight to his teenage criminal history, contrary to the IRAA’s purpose. The appellate court held that these errors, in combination, undermined confidence in the trial court’s decision and were not harmless.The District of Columbia Court of Appeals vacated the Superior Court’s order and remanded the case for reconsideration consistent with its opinion. View "Bryant v. United States" on Justia Law

Green Theory LLC applied for a license to operate a medical cannabis dispensary at a location in Washington, D.C. While the application was pending, a group of local residents, including parents and school administrators, collectively known as the Wolverton Group, filed a protest with the District of Columbia Alcoholic Beverage and Cannabis Board. They argued that the proposed dispensary was within 1,000 feet of several schools, raising concerns about the impact on the community and potential violations of federal law. The local Advisory Neighborhood Commission (ANC) did not oppose the application.The Alcoholic Beverage and Cannabis Board dismissed the Wolverton Group’s protest, reasoning that under the Medical Cannabis Amendment Act of 2022, only affected ANCs had standing to protest such license applications. The Board then approved Green Theory’s license. The Wolverton Group and other petitioners sought reconsideration and a stay, both of which were denied. They then filed a petition for review with the District of Columbia Court of Appeals, arguing that the Board’s interpretation of the statute was incorrect and unconstitutional, and that the Board’s decision was arbitrary and capricious.The District of Columbia Court of Appeals reviewed whether it had jurisdiction to consider the petition. The court determined that its jurisdiction is limited to “contested cases,” which require a trial-type hearing mandated by statute, regulation, or constitutional right. The court found that the relevant statute only required such a hearing if an ANC filed a protest, which did not occur. The court also rejected arguments that a hearing was required by regulation or constitutional right. Concluding that this was not a contested case, the court held it lacked jurisdiction and dismissed the petition for review. View "1000 Feet DC Inc. v. D.C. Alcoholic Beverage and Cannabis Board" on Justia Law

A nonprofit organization focused on corporate accountability brought suit against a California-based company that exports açaí products, alleging that the company made false and misleading statements about the labor conditions in its supply chain. The complaint asserted that the company’s marketing materials claimed its products were ethically sourced and free from child labor, but the nonprofit alleged these claims were not supported by the realities of the supply chain, including reports that the company purchased fruit from sources outside its registered network without verifying labor conditions.The Superior Court of the District of Columbia reviewed the case after the company moved to dismiss, arguing that California’s Unfair Competition Law (UCL) should apply under District of Columbia choice-of-law rules, and that the nonprofit lacked standing under the UCL. The trial court agreed, finding a conflict between the District’s Consumer Protection Procedures Act (CPPA) and the UCL, and concluded that the UCL applied because the relevant conduct and parties’ connections were centered in California. The court then dismissed the complaint, holding that the nonprofit lacked standing under the UCL, which does not provide for associational standing unless the organization has suffered a loss of money or property.On appeal, the District of Columbia Court of Appeals held that the nonprofit failed to preserve its argument that there was no true conflict between the CPPA and the UCL, so the court assumed a conflict existed. However, the appellate court found that the trial court erred in determining, at the motion to dismiss stage, that the UCL should apply. The appellate court held that, given the limited factual record, it was premature to resolve the choice-of-law issue against the nonprofit, and that the law of the forum (the CPPA) should apply unless further development shows otherwise. The order dismissing the case was reversed and remanded for further proceedings. View "Corporate Accountability Lab v. Sambazon, Inc." on Justia Law

The case concerns an individual who was implicated in a fatal shootout between two rival gangs in a District of Columbia housing complex. The incident resulted in the death of a bystander. The government’s case against the appellant relied on evidence that he was either the mastermind behind the gun battle, the first shooter, or that he armed himself and lay in wait for the confrontation. The trial featured conflicting witness testimony regarding who initiated the shooting and the appellant’s precise role. Ultimately, the appellant was acquitted of second-degree murder and conspiracy to commit murder but was convicted of voluntary manslaughter while armed and related firearms offenses.After his conviction, the appellant pursued direct appeal, during which the District of Columbia Court of Appeals significantly changed the legal standard for causation in such cases in Fleming v. United States, replacing the “substantial factor” test with a stricter “but-for” causation requirement. The appellant attempted to challenge his conviction based on this new standard, but the appellate court directed him to file a motion under D.C. Code § 23-110 in Superior Court. The Superior Court denied his motion, finding that although he had cause for not raising the issue earlier, he was not prejudiced by the instructional error, as the evidence was deemed sufficient for conviction under the new standard.The District of Columbia Court of Appeals reviewed the case and held that the trial court erred in denying the appellant’s motion. The appellate court found that the instructional error regarding causation was not harmless and that there was a reasonable probability the jury would not have convicted the appellant if properly instructed under the “but-for” standard. The court vacated the convictions for voluntary manslaughter while armed and possession of a firearm during a crime of violence, remanding the case for further proceedings. View "Parker v. United States" on Justia Law

A divorced couple with three minor children, who reside full-time with their mother, entered into a child-support agreement as part of their divorce proceedings. The agreement, incorporated into a final order, calculated child support using a formula established in a prior case, which is applied when the parents’ combined adjusted gross income exceeds $240,000. Over time, both parties filed motions seeking to modify child support, compel discovery, and request sanctions, primarily due to alleged changes in income and discovery disputes. The father sought a reduction in support based on his income, while the mother sought enforcement and additional relief, including attorney’s fees and sanctions.The Superior Court of the District of Columbia held hearings, issued a temporary reduction in the father’s support obligation, and ultimately entered a permanent order requiring him to pay $3,817.28 per month. The court used the Holland formula to determine the support amount, declined to “gross up” the father’s nontaxable veteran’s benefit for tax purposes, and excluded a $6,000 extraordinary medical expense from the calculation due to insufficient evidence. The court also denied the mother’s requests for attorney’s fees and sanctions, often without detailed explanation.On appeal, the District of Columbia Court of Appeals affirmed the trial court’s use of the Holland formula, holding that it was within the court’s discretion for high-income cases. However, the appellate court vacated the permanent support order and remanded for further proceedings. It held that the trial court erred by not grossing up the father’s nontaxable veteran’s benefit as required by statute, by not adequately considering the extraordinary medical expense, and by failing to properly address the mother’s requests for attorney’s fees and sanctions. The case was remanded for the trial court to address these issues in accordance with the appellate court’s guidance. View "Hershey v. Hershey" on Justia Law

In this case, the appellant hired the appellee, an attorney, in 2017 to represent her in a federal disability discrimination lawsuit against her former employer. The federal district court granted summary judgment to the employer on some claims and dismissed the remaining claim at the appellant’s request in May 2019, closing the case. Over three years later, in June 2022, the appellant filed a lawsuit in the Superior Court of the District of Columbia, alleging legal malpractice and breach of contract, claiming that the attorney’s deficient representation caused her to lose her federal case.The appellee moved to dismiss the complaint, arguing that the claims were barred by the three-year statute of limitations. The Superior Court initially denied the motion, suggesting that COVID-19 tolling orders might have paused the limitations period. However, after the appellant filed an amended complaint and the appellee renewed the motion to dismiss—which the appellant did not oppose—the court reconsidered and dismissed the complaint as untimely. The court found that the COVID-19 tolling orders did not apply because the limitations period did not expire during the relevant emergency period, and that the claims were time-barred under any possible accrual date. The appellant’s motion for reconsideration, based on excusable neglect due to personal issues, was denied.On appeal, the District of Columbia Court of Appeals affirmed the Superior Court’s judgment. The court held that the appellant’s claims were untimely under the applicable statute of limitations, that neither the COVID-19 tolling orders nor claims of excusable neglect, non compos mentis status, or the discovery rule justified tolling the limitations period, and that no extraordinary circumstances warranted relief under Rule 60(b)(1). The judgment of dismissal was affirmed. View "Baskin v. Pitre" on Justia Law