Justia District of Columbia Court of Appeals Opinion Summaries

When Riley S. Walls was eighteen, he committed first-degree murder, assault with intent to kill, and possession of a firearm during a crime of violence. He received three consecutive sentences totaling forty-five years to life. Now in his 50s, Walls sought a sentence reduction under the Incarceration Reduction Amendment Act (IRAA), effectively requesting immediate release. To obtain IRAA relief, movants must demonstrate they are no longer a danger to the community and that the interests of justice warrant a sentence reduction. The trial court and parties agreed that the indeterminate sentencing scheme was applicable.The Superior Court of the District of Columbia partially granted Walls’s IRAA request. The court found that Walls was no longer dangerous and that the interests of justice favored a sentence reduction. However, it determined that Walls was not ready for immediate release and would benefit from further time and support within the correctional system. Consequently, the court reduced Walls’s sentence by ten years, making him eligible for parole in 2027.The District of Columbia Court of Appeals vacated the trial court’s order and remanded the case for further consideration. The appellate court found that the trial court erred by basing its decision on the notion that further imprisonment would benefit Walls, which is inconsistent with IRAA’s directives. Additionally, the trial court imposed an illegal sentence by reducing Walls’s indeterminate sentence for first-degree murder to twenty years to life, exceeding the statutory maximum-minimum sentence of fifteen years. The appellate court directed the trial court to reconsider the extent of Walls’s sentence reduction without considering the benefits of further imprisonment and to modify Walls’s sentence in accordance with the indeterminate sentencing guidelines. View "Walls v. United States" on Justia Law

Jesse R. Redmond, Jr. was convicted by a jury of sexually assaulting his neighbor, B.R. Redmond later filed a motion to vacate his conviction, arguing that the government knowingly introduced false or misleading evidence by allowing an expert witness to testify that a hair found at the crime scene was consistent with his hair. Redmond contended that this testimony was material to the jury’s verdict.The Superior Court of the District of Columbia denied Redmond’s motion, agreeing with the government that the expert’s testimony was not material to the verdict. The court found that the testimony was brief, the prosecutor did not emphasize it in closing arguments, and there was overwhelming independent evidence of Redmond’s guilt, including B.R.’s identifications and Redmond’s own statements placing him at B.R.’s house.The District of Columbia Court of Appeals reviewed the case and concluded that the expert’s testimony was indeed material to the verdict. The court noted that the expert’s testimony was presented as authoritative and was the last evidence the jury heard before deliberations. The court also found that the other evidence of Redmond’s guilt was not overwhelming, as the jury had acquitted him on two of the three charges and had been deadlocked for some time. The court held that the government had not proven that the admission of the false or misleading testimony was harmless beyond a reasonable doubt.The court rejected the government’s argument that the more lenient harmless error standard from Brecht v. Abrahamson should apply to Redmond’s post-conviction motion. The court held that Napue violations, which involve the knowing presentation of false or misleading testimony, are reviewed for materiality under the stricter Chapman v. California standard and are not subject to further review for harmless error under Brecht. The court vacated Redmond’s conviction and remanded for a new trial. View "Redmond v. United States" on Justia Law

The appellant, Delvin T. Neal, was convicted of robbery in the Superior Court of the District of Columbia. Neal, a barber, had a long-standing client, Andrew Street, who sold watches. Neal purchased a Hublot watch from Street for $1,000, which was later found to be fake. Neal attempted to get a refund, but Street refused. Subsequently, Neal arranged to meet Street at his barbershop to discuss another watch. During this meeting, Neal assaulted Street and, with the help of two unknown men, took Street's watch, earrings, and chain. Neal also took Street's mother, Sillette Sheler's, wallet and refused to return it unless she paid him $1,000.The jury in the Superior Court found Neal guilty of robbing Sheler's wallet but acquitted him of robbing and assaulting Street. Neal appealed, arguing that the trial court failed to properly instruct the jury on the intent to steal and that he had a claim-of-right defense.The District of Columbia Court of Appeals reviewed the case. Neal contended that the jury instructions on intent to steal were inadequate. The court applied plain-error review and found no plain error, noting that the instructions given were sufficient and that Neal's actions demonstrated an intent to steal as he demanded $1,000 for the return of Sheler's wallet.Neal also argued that he should have been given a claim-of-right defense instruction, asserting he believed he had the right to take Sheler's wallet to recover his money. The court rejected this argument, holding that the claim-of-right defense does not apply when a defendant takes unrelated property to coerce payment of a debt.The court concluded that there was sufficient evidence to support Neal's conviction for robbery, as his actions met the criteria for intent to steal. The District of Columbia Court of Appeals affirmed Neal's conviction. View "Neal v. United States" on Justia Law

Marcus Ford was charged with several drug-related offenses after officers seized a vial of PCP and multiple baggies of cocaine from his pants pocket in his apartment building. Ford moved to suppress the evidence, arguing that he withdrew his initial consent to the search by putting his hand on his pocket as the officer touched a suspicious bulge. The trial court denied the motion, finding the encounter consensual until the drugs were seized.Ford appealed, and the District of Columbia Court of Appeals concluded that the trial court erred in ruling that Ford's actions did not revoke consent. The case was remanded for additional findings on whether the officer had a lawful basis for searching Ford's pocket. On remand, the trial court found that the search was supported by probable cause, citing the officers' experience, known drug activity in the building, and Ford's movements.In the current appeal, the District of Columbia Court of Appeals reviewed the trial court's denial of the motion to suppress. The court held that the trial court improperly considered Ford's revocation of consent as support for probable cause. The court emphasized that a suspect's exercise of the right to withdraw consent cannot be used to establish probable cause. Without considering the revocation of consent, the court found that the seizure of drugs was not justified under the plain feel doctrine, as the incriminating nature of the object was not immediately apparent to the officer.The District of Columbia Court of Appeals vacated Ford's convictions and remanded the case for further proceedings consistent with its opinion. View "Ford v. United States" on Justia Law

The case involves the District of Columbia's Consumer Protection Procedures Act (CPPA) claims against Facebook, Inc. stemming from the Cambridge Analytica data leak. In 2018, it was revealed that Cambridge Analytica had improperly obtained data from millions of Facebook users through a third-party application developed by Aleksandr Kogan. The District of Columbia alleged that Facebook violated the CPPA by unintentionally misleading consumers about data accessibility to third-party applications, Facebook's enforcement capabilities, and failing to disclose the data breach in a timely manner.The Superior Court of the District of Columbia granted summary judgment in favor of Facebook, concluding that the District had to prove its CPPA claims by clear and convincing evidence. The court found that Facebook's disclosures were accurate and that no reasonable consumer could have been misled. Additionally, the court excluded the testimony of the District's expert witness, Dr. Florian Schaub, criticizing his analytical methods and analysis.The District of Columbia Court of Appeals reviewed the case and held that CPPA claims based on unintentional misrepresentations need only be proved by a preponderance of the evidence, not by clear and convincing evidence. The court reversed the trial court's summary judgment decision and remanded the case for reconsideration under the correct burden of proof. The appellate court also reversed the trial court's exclusion of Dr. Schaub's testimony, finding that the trial court's reasoning was insufficient and remanded for further analysis and explanation.The main holding of the District of Columbia Court of Appeals is that CPPA claims based on unintentional misrepresentations require proof by a preponderance of the evidence, and the exclusion of expert testimony must be supported by a thorough analysis consistent with the standards set forth in Motorola Inc. v. Murray. View "District of Columbia v. Facebook, Inc." on Justia Law

Lezah Roberts entered into a fixed-price contract with Advanced Building Design, a Maryland-based firm, to build a handicap-accessible addition to her home in the District of Columbia. The project, which began in 2017 and was expected to take six months, remained unfinished nearly two years later. The project went over budget due to price increases and change orders, and Advanced sought to recoup these overages from Roberts. After initially agreeing to cover some additional costs, Roberts eventually refused to pay further increases, leading Advanced to cease work on the project. Roberts then filed a complaint in the Superior Court of the District of Columbia, alleging breach of contract, fraudulent misrepresentation, breach of the implied covenant of good faith and fair dealing, and a claim under the D.C. Consumer Protection Procedures Act (CPPA) for unfair trade practices.The Superior Court granted Advanced’s motion to dismiss Roberts’s suit, citing a mandatory forum selection clause in the contract that designated Maryland as the exclusive forum for litigation. Roberts appealed, arguing that the forum selection clause was unenforceable because it conflicted with the CPPA and was unconscionable.The District of Columbia Court of Appeals reviewed the case and disagreed with Roberts on both counts. The court held that the CPPA does not preclude parties from selecting their preferred forum and that the forum selection clause did not contravene public policy or demonstrate procedural or substantive unconscionability. Consequently, the court affirmed the Superior Court’s dismissal of Roberts’s complaint. View "Roberts v. Advanced Building Design" on Justia Law

Linda Jenkins was injured when she slipped and fell on a wet floor being mopped by an employee of Red Coats, Inc. She did not see a wet floor sign in the area and suffered neck, back, and leg injuries. Jenkins sued Jemal’s Atlantic, LLC, and LPC Commercial Services, Inc. for negligence, but the trial court granted summary judgment in favor of the defendants, a decision which was affirmed on appeal. Jenkins also sued Red Coats for negligence and negligent hiring, training, retention, and supervision. The trial court dismissed the latter claim, and this dismissal was affirmed on appeal. For the negligence claim, the trial court granted summary judgment for Red Coats, stating Jenkins needed expert testimony to establish the standard of care.The Superior Court of the District of Columbia initially granted summary judgment for Red Coats, stating Jenkins needed expert testimony to establish the standard of care. This decision was vacated and remanded for further consideration. On remand, the trial court reaffirmed its decision, concluding that expert testimony was necessary because the actions Red Coats should have taken beyond placing a wet floor sign were beyond the understanding of an average layperson.The District of Columbia Court of Appeals reviewed the case and found that the trial court abused its discretion. The appellate court held that in typical slip and fall cases, laypeople do not require expert assistance to determine if a warning was adequate. The court concluded that a jury could evaluate whether Red Coats exercised reasonable care in warning passersby of the hazard caused by the wet floor based on common knowledge and everyday experience. Therefore, Jenkins’s failure to provide expert testimony was not fatal to her claim. The judgment of the Superior Court was vacated, and the case was remanded for trial. View "Jenkins v. Red Coats, Inc." on Justia Law

In this case, Michael Patrick Murray and other plaintiffs, who either suffer from brain tumors or represent estates of decedents who died from brain cancer, sued Motorola, Inc. and other telecommunications companies. They alleged that long-term exposure to cell phone radiation caused their health issues. The litigation began in 2001 and has been through multiple appeals. In a previous decision, the court allowed the litigation to proceed, and in another, it changed the evidentiary standard for admitting expert testimony from the "general acceptance" test to the "reliability" test.The Superior Court of the District of Columbia, post-remand, denied the plaintiffs' motions for additional discovery and to add new experts, struck portions of their supplemental expert reports, excluded all of their expert testimony under Rule 702, and granted summary judgment in favor of the defendants. The trial judges ruled that the plaintiffs failed to provide admissible expert testimony on general causation, which was necessary to proceed with the case.The District of Columbia Court of Appeals reviewed the case and affirmed the trial court's decisions. The appellate court found no abuse of discretion in the trial judges' rulings on discovery and expert testimony. The court held that the trial judges correctly applied the legal principles and managed the discovery process appropriately. The appellate court also agreed that the plaintiffs failed to meet the standards set out in Rule 702 for their expert testimony, and thus, summary judgment for the defendants was appropriate. View "Murray v. Motorola, Inc." on Justia Law

The case involves MP PPH, LLC, the owner of the Marbury Plaza apartment complex in Washington, D.C., which was found in contempt by the Superior Court of the District of Columbia for failing to comply with a consent order. The consent order was designed to address severe housing code violations, including pest infestations, mold, broken air conditioning, lack of heat, unsecured doors, leaks, and major plumbing issues. The trial court ordered a 50% rent abatement for all tenants, retroactive to the latest possible date by which MP PPH had agreed to complete the consent order’s requirements.The Superior Court of the District of Columbia initially denied the District of Columbia’s motion for contempt, finding that MP PPH had made good faith efforts to comply. However, upon a renewed motion, the court held a three-day evidentiary hearing and found MP PPH in contempt, citing extensive noncompliance with the consent order. The court noted that MP PPH had failed to conduct proper mold assessments, complete necessary repairs, and provide pest control services, among other violations. The court imposed sanctions, including a 50% rent abatement for all tenants, increasing to 60% and then 75% if compliance was not achieved within specified timeframes.The District of Columbia Court of Appeals reviewed the case and affirmed the trial court’s contempt finding and sanctions. The appellate court found that the evidence of MP PPH’s contempt was overwhelming and that the trial court was not required to follow a three-step contempt process as argued by MP PPH. The court also held that the trial court’s sanctions did not interfere with the discretion of courts presiding over related landlord-tenant cases and that any improper reference to the wealth of MP PPH’s principal was harmless. The appellate court concluded that MP PPH had forfeited many of its arguments on appeal by not raising them in a timely manner before the trial court. View "MP PPH, LLC v. District of Columbia" on Justia Law

In this case, 4022 Georgia Avenue, LLC (4022 LLC) acquired a townhouse in Washington, D.C., in April 2018, which it later sold in two units in 2020. In June 2021, the new owners reported significant structural issues, leading to an inspection by the Department of Consumer and Regulatory Affairs (DCRA). DCRA issued an order to correct (December OTC) to 4022 LLC in December 2021, directing it to address various building code violations. 4022 LLC appealed the order, arguing it could not comply without the cooperation of the new owners.The Office of Administrative Hearings (OAH) held a hearing in April 2024 and issued a final order in May 2024, affirming the December OTC. OAH found that 4022 LLC's appeal did not meet the criteria for appeals under the relevant regulations, as it did not specify which provisions of the building code were incorrectly interpreted or applied. OAH also found that 4022 LLC was responsible for the violations due to its warranty obligations under the Condominium Act.The District of Columbia Court of Appeals reviewed the case and held that OAH did not err in its findings. The court concluded that 4022 LLC's failure to identify specific provisions of the building code in its appeal constituted a failure to comply with the criteria for appeals. The court also found that OAH's reliance on the Property Maintenance Code, instead of the Building Code, did not constitute reversible error, as the criteria for appeals were substantively similar. Finally, the court held that OAH did not err in finding 4022 LLC responsible for the violations, as substantial evidence supported this finding based on the LLC's warranty obligations.The court affirmed OAH's order, upholding the December OTC and the requirement for 4022 LLC to address the building code violations. View "4022 Georgia Avenue v. Department of Buildings" on Justia Law