Justia District of Columbia Court of Appeals Opinion Summaries

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

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