Justia Civil Procedure Opinion Summaries

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

Jacqueline Martin and Herbert McCray were in a romantic relationship for over four decades until Jacqueline's death in 2020. Jacqueline died without a will, and Herbert sought to administer and inherit her estate, claiming they were common law married. Herbert died before the matter was resolved, and his son, Brian McCray, sought to continue Herbert's claim. Jacqueline's first cousin, Juanita Waller, contested this, arguing that Jacqueline and Herbert were not common law married and that she was the next of kin.The Superior Court of the District of Columbia, Probate Division, appointed Juanita as the personal representative of Jacqueline's estate, concluding that Juanita had priority over Brian. The court then held a trial to determine if Jacqueline and Herbert were common law married. The trial court limited the evidence to direct proof of an express mutual agreement in the present tense to be permanent partners. The court ruled in favor of Juanita, finding no such express mutual agreement.The District of Columbia Court of Appeals reviewed the case. The court held that the trial court erred by precluding Brian from introducing circumstantial evidence that could infer an express mutual agreement. The appellate court noted that when neither partner is available to testify, such an agreement may be inferred from the circumstances surrounding the couple’s relationship, including their cohabitation and reputation in the community. The court reversed the trial court's judgment and remanded the case for a new trial, allowing Brian to present relevant circumstantial evidence. The appellate court affirmed the appointment of Juanita as the personal representative of Jacqueline's estate. View "In re Estate of Martin" on Justia Law

Ms. Wilson owned a property in the District of Columbia, which she subdivided into three lots: 825, 826, and 827. She sold Lot 826 to Ntaky Management in 2009 and Lot 825 to Ms. Lumbih in 2010. The deed for Lot 826 described it as measuring twenty feet by forty feet, while the deed for Lot 825 described it as thirty-eight feet in length, based on an informal survey by Vyfhuis & Associates. This created a disputed area of eight feet between the properties. Ms. Lumbih installed an HVAC unit and deck in this disputed area. In 2018, Ntaky asked Ms. Lumbih to remove these installations, but she did not comply, leading Ntaky to sue her.The Superior Court of the District of Columbia held a non-jury trial and ruled that Ntaky owned the disputed area and could remove the encroachments at Ms. Lumbih’s expense. The court also denied Ms. Lumbih’s breach-of-contract claim against Ms. Wilson and her claim for implied indemnity, which sought to hold Ms. Wilson responsible for the costs associated with removing the encroachments.The District of Columbia Court of Appeals reviewed the case. The court upheld the trial court’s decision regarding Ntaky’s ownership of the disputed area and the removal of the encroachments. However, it vacated the denial of Ms. Lumbih’s breach-of-contract claim against Ms. Wilson, finding that the trial court did not address whether Ms. Wilson breached her duty to convey a property thirty-eight feet in length. The case was remanded for further proceedings on this issue. The court affirmed the trial court’s denial of Ms. Lumbih’s claim for implied indemnity, as she failed to identify a non-contractual duty of care owed by Ms. Wilson. View "Lumbih v. Wilson" on Justia Law

Sarah Staab purchased a condominium unit at a foreclosure sale conducted by the condominium association to recover unpaid fees. She later challenged two Superior Court orders that ruled the sale of the unit to her was barred by the Federal Foreclosure Bar, 12 U.S.C. § 4617(j)(3), and thus void, and granted summary judgment to Wells Fargo Bank, N.A. on its claims for judicial foreclosure, declaratory judgment, and quiet title. Staab did not contest that the property was encumbered by a deed of trust owned by the Federal Housing Finance Agency (FHFA) and the Federal National Mortgage Association (Fannie Mae) and serviced by Wells Fargo, nor did she dispute the application of the Federal Foreclosure Bar. Instead, she raised three procedural arguments.The Superior Court of the District of Columbia initially ruled in favor of Wells Fargo, determining that the bank's claims were timely, the foreclosure and sale of the property to Staab were void under the Federal Foreclosure Bar, and the condominium association was not an indispensable party. Staab argued that the court applied the incorrect statute of limitations, abused its discretion by allowing Wells Fargo to amend its complaint years after filing, and erred by not joining the condominium association as an indispensable party.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court's judgment. The court held that Wells Fargo's initial action for judicial foreclosure was timely and that the additional facts and arguments raised in the amended complaint were in direct response to Staab's affirmative defense. The court also concluded that any error in granting Wells Fargo leave to amend its complaint was harmless, as the bank could have raised the same arguments at the summary judgment stage. Finally, the court determined that the condominium association was not an essential party under Super. Ct. Civ. R. 19(a)(1), as the court could grant complete relief without its involvement. View "Staab v. Wells Fargo Bank, N.A." on Justia Law

Leroy Williams, a special police officer with the D.C. Department of General Services (DGS), was terminated in August 2019 for conduct related to unauthorized traffic stops. He was given three options to appeal: filing an appeal with the Office of Employee Appeals, having his union (Fraternal Order of Police, FOP) file a grievance, or filing a grievance personally. Williams chose the second option, and FOP filed a grievance on his behalf. When the grievance could not be settled, it was advanced to arbitration, where the arbitrator upheld Williams's termination.FOP then sought review from the Public Employee Relations Board (PERB), which upheld the arbitrator's decision. FOP subsequently petitioned the Superior Court of the District of Columbia for review, which affirmed PERB's decision. After FOP's counsel withdrew, Williams filed an appeal to the District of Columbia Court of Appeals on his own.The District of Columbia Court of Appeals reviewed whether Williams had standing to bring the appeal. The court noted that the collective bargaining agreement granted the union the sole authority to arbitrate grievances and, consequently, the sole authority to appeal arbitration decisions. The court found that Williams lacked standing to appeal because only the union could pursue such an appeal unless the union breached its duty of fair representation, which was not argued in this case.The court dismissed Williams's appeal for lack of standing, concluding that he could not independently challenge the arbitration award under the terms of the collective bargaining agreement. View "Williams v. Department of General Services" on Justia Law