Justia Civil Procedure Opinion Summaries

Peter Farina has lived at the Victor Howell House, a group home for low-income individuals, since 1989. In 2000, the Janet Keenan Housing Corporation (JKHC), a non-profit, purchased the property to maintain it as affordable housing. Recently, JKHC attempted to sell the house to a private third party, leading to two tracks of litigation. The District of Columbia sued JKHC to halt the sale, arguing it violated JKHC’s charitable purposes. As the District and JKHC neared a settlement allowing the sale, Farina sought to intervene but was denied. Farina then filed his own lawsuit, claiming his rights under the Tenant Opportunity to Purchase Act (TOPA) and the Uniform Trust Code (UTC) were being violated.The Superior Court of the District of Columbia denied Farina’s motion to intervene in the District’s case, citing untimeliness and lack of standing. The court approved the settlement between the District and JKHC, which allowed the sale to proceed. In Farina’s separate lawsuit, the court ruled against him, stating his TOPA rights were extinguished by the court-approved settlement and that he lacked standing to bring his UTC claim.The District of Columbia Court of Appeals reviewed the case. The court held that Farina’s TOPA rights were not extinguished by the settlement, as the sale was an arm’s-length transaction and not exempt under TOPA. Farina must be given the opportunity to purchase the property under TOPA. However, the court agreed with the lower court that Farina lacked standing to bring his UTC claim, as he was neither a settlor nor a special interest beneficiary of JKHC. The court affirmed the judgment in the District’s case but vacated the judgment in Farina’s case, remanding it for further proceedings to afford Farina his TOPA rights. View "Farina v. Janet Keenan Housing Corporation" on Justia Law

John T. McFarland, a Program Support Specialist with the Department of Consumer and Regulatory Affairs (DCRA), requested a reclassification of his Grade 9 position to Grade 11 in 2011. The desk audit for this request was delayed, and the initial reviewer, Peter Delate, was replaced by Lewis Norman, who completed the audit in 2013 and concluded that the Grade 9 classification was correct. McFarland appealed this decision, but the Director of the District of Columbia’s Department of Human Resources (DCHR) upheld it. McFarland then petitioned for review in Superior Court, which affirmed DCHR’s decision. McFarland appealed to the District of Columbia Court of Appeals, which also affirmed the decision.In 2017, McFarland filed another petition in Superior Court, presenting new documents obtained through a Freedom of Information Act request that suggested Delate had initially supported a Grade 11 classification. The Superior Court vacated DCHR’s decision and remanded the case for reconsideration. On remand, a new specialist reviewed the entire record and concluded that McFarland’s position was correctly classified as Grade 9. McFarland again petitioned for review in Superior Court, which denied his petition and his motion for sanctions against the District of Columbia.The District of Columbia Court of Appeals reviewed the case and concluded that the Superior Court lacked jurisdiction to entertain McFarland’s petition for review under the Comprehensive Merit Personnel Act (CMPA), as the classification decision did not involve a reduction in grade. The court also found that McFarland had not shown that the Superior Court erred in denying his motion for sanctions. The Court of Appeals affirmed the denial of sanctions and remanded the case for dismissal of the petition for review for lack of jurisdiction. View "McFarland v. District of Columbia, Department of Human Resources" 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

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

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

Samuel Murray, a motor-vehicle operator for the District of Columbia Department of Youth Rehabilitation Services (DYRS), was wrongfully terminated after taking leave due to an injury sustained at work. In September 2020, DYRS was ordered to reinstate Mr. Murray and awarded him back-pay with benefits. Mr. Murray did not initially request interest on the back-pay. In February 2021, he petitioned the Office of Employee Appeals (OEA) to reopen his case for enforcement of the back-pay and benefits, which had not yet been provided, and for the first time sought accrued interest on the back-pay.The OEA Administrative Judge (AJ) ruled that OEA had the authority to award interest on back-pay and ordered DYRS to pay Mr. Murray prejudgment interest. DYRS sought review in the Superior Court, which reversed the AJ's decision, holding that the AJ did not have jurisdiction to grant interest on the back-pay award. The Superior Court reasoned that the AJ's jurisdiction was limited to correcting the record, ruling on attorney fees, or processing enforcement petitions, and Mr. Murray's request for prejudgment interest fell outside these parameters.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court's judgment. The court held that D.C. Code § 1-606.03(c) clearly precluded Mr. Murray's belated request for prejudgment interest, as it was made over three months after the back-pay award became final and did not fall within the AJ's limited post-award jurisdiction. The court also noted that it did not address whether OEA has the authority to award prejudgment interest when timely requested or whether post-judgment interest could be part of enforcing an award not promptly paid. View "Murray v. District of Columbia Dep't of Youth and Rehabilitation Services" on Justia Law

Appellants Marilyn Kubichek and Dorothy Baldwin were injured on October 11, 2019, when they were struck by a Segway operated by Eduardo Samonte during a guided tour run by Unlimited Biking Washington, D.C., LLC. They filed two complaints on December 30, 2022, alleging negligence by Samonte and failure to train and supervise by Unlimited Biking. The complaints were filed after the three-year statute of limitations for negligence had expired.The Superior Court of the District of Columbia consolidated the two cases and granted Samonte's motion to dismiss, concluding that the COVID-19 emergency orders did not toll the statute of limitations for the appellants' claims. The court determined that the tolling orders only applied to deadlines that fell within the tolling period or arose from claims that accrued during the tolling period. Since the Segway accident occurred before the tolling period began and the statutory deadline was after the tolling period expired, the court ruled that the limitations period was not tolled.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court's decision. The Court of Appeals held that the statute of limitations is an affirmative defense that must be raised by the defendant and should not be raised sua sponte by the court. However, in this case, the trial court did not act entirely sua sponte because Samonte had asserted the limitations defense, and the appellants had the opportunity to litigate the issue. The Court of Appeals also confirmed that the Superior Court's tolling orders during the COVID-19 pandemic did not toll the limitations period for the appellants' negligence claims, as the orders only applied to deadlines that expired during the emergency period, which was not the case here. The dismissal of the complaints was affirmed. View "Kubichek v. Unlimited Biking Washington, DC, LLC" on Justia Law

Appellant Charles E. Wilson filed a lawsuit against the District of Columbia Board of Elections, Mayor Muriel E. Bowser, and the District of Columbia, challenging the proposed ballot Initiative 83, also known as the “Make All Votes Count Act of 2024.” Wilson objected to the initiative’s summary statement, short title, and legislative form, and raised several challenges to the Board’s determination that the initiative was a “proper subject” for an initiative. The initiative, which proposed ranked-choice voting and changes to primary election rules, was approved by voters on November 5, 2024.The Superior Court of the District of Columbia dismissed Wilson’s complaint, ruling it was untimely because it was filed the day before the ten-day period described in D.C. Code § 1-1001.16(e)(1)(A) began. The court concluded it lacked jurisdiction to hear the case because the complaint was not filed within the specified timeframe.The District of Columbia Court of Appeals reviewed the case and concluded that the ten-day period described in Subsection (e)(1)(A) is a claim-processing rule rather than a jurisdictional rule. The court determined that the ten-day period is a deadline by which any suit must be filed, rather than a time window during which a suit must be brought. The court also held that the Superior Court had general equity jurisdiction to hear Wilson’s substantive challenges to the Board’s “proper subject” determination. However, the court affirmed the dismissal of the claims against the Mayor and the District of Columbia, as they were not proper defendants in this case.The Court of Appeals vacated the Superior Court’s order dismissing the complaint and remanded the case for further proceedings to address Wilson’s claims against the Board of Elections. View "Wilson v. Bowser" on Justia Law

A national news reporter employed by a prominent newspaper sued her employer and six of its editors in Superior Court, alleging violations of the D.C. Human Rights Act and the common law tort of negligent infliction of emotional distress. She claimed that the defendants discriminated against her based on her status as a sexual assault victim and her gender, took adverse employment actions against her, subjected her to a hostile work environment, and retaliated against her for protesting their discriminatory actions.The defendants moved to dismiss the complaint under Superior Court Civil Rule 12(b)(6) for failure to state a claim and filed a special motion to dismiss under the D.C. Anti-SLAPP Act, arguing that the claims arose from acts in furtherance of the right of advocacy on issues of public interest. The Superior Court denied the special motion to dismiss, finding that the claims did not arise from speech protected by the Anti-SLAPP Act, but granted the Rule 12(b)(6) motion, concluding that the complaint failed to plausibly allege unlawful discrimination or retaliation.The District of Columbia Court of Appeals reviewed the case and affirmed the denial of the special motion to dismiss, agreeing that the Anti-SLAPP Act did not apply. The court reversed the dismissal of the counts alleging adverse action discrimination, finding that the complaint plausibly alleged that the defendants took certain adverse employment actions against the reporter in violation of the Human Rights Act. However, the court affirmed the dismissal of the hostile work environment and retaliation claims, concluding that the allegations did not meet the necessary legal standards. The court also noted that it was premature to decide whether the defendants' actions were protected by the First Amendment, leaving that issue open for further proceedings. View "Sonmez v. WP Company, LLC" on Justia Law