In Eady v. United States, Carlos Eady appealed his convictions for carrying a pistol without a license, possession of an unregistered firearm, and possession of ammunition, which carried sentencing enhancements due to a prior felony conviction and the fact that the offenses were committed while on release in another case. The trial judge read the unredacted indictment to the jury, instructed the jury on and allowed the prosecutor to reference Eady’s prior felony and release status, and provided the jury with written copies of stipulations admitting those facts. Eady argued this exposed the jury to unnecessary and prejudicial details about his criminal history. The D.C. Court of Appeals agreed, holding that the jury had been improperly informed of the prior conviction and release status in violation of rules limiting such evidence, and therefore reversed the convictions and remanded for a new trial.
The case involved Victor Onyeoziri’s challenge to the foreclosure sale of his District of Columbia property by trustees Spivok and Collins on behalf of lender BB&T. Onyeoziri had obtained a $125,000 business loan secured by the property; after he defaulted, the trustees proceeded with a foreclosure auction despite his claim that he had a pending contract to sell the house for $280,000. The Superior Court granted summary judgment to the defendants on all counts. On appeal, the D.C. Court of Appeals affirmed summary judgment on the federal Truth in Lending Act and D.C. Home Loan Protection Act claims, holding that the loan was a commercial transaction outside the statutes’ consumer protections and that an exculpatory clause in the forbearance agreement further barred those claims. The court reversed and remanded on the tortious interference claim, concluding that Onyeoziri had presented sufficient evidence of a specific, nearly finalized sales contract and questions of fact about notice and the trustees’ conduct to create a triable issue.
In Jones v. United States, a jury convicted Ricardo Jones of first-degree murder while armed and related weapons offenses for fatally shooting David Valentine during a confrontation in Washington, D.C., on July 6, 2005, as well as escape; Jones appealed, challenging the trial court's admission of evidence from a subsequent armed robbery in North Carolina, expert testimony on firearm and toolmark identification, and limits on cross-examining government witnesses for bias. The District of Columbia Court of Appeals affirmed the convictions. The court held that the North Carolina evidence was properly admitted as it corroborated Jones's identity as the shooter, his possession and use of the specific .45-caliber pistol, and other details through independent witness accounts and physical evidence, with its probative value outweighing any prejudice; it also found no error in allowing the expert testimony or restricting the cross-examination, and no other grounds for reversal.
This case arose from a medical malpractice action in which patient Rosalee Blue sued surgeon Dr. Ronald Kurstin and anesthesiologist Dr. John Lordan as joint tortfeasors for injuries caused by administration of Lovenox during hernia repair surgery. Blue settled with Lordan for $2 million under an agreement that dismissed all claims against both doctors but expressly reserved Lordan’s right to pursue contribution from Kurstin, with any recovery to be assigned back to Blue; the malpractice trial was then converted to a bench trial on the contribution cross-claim. The trial court found Kurstin had breached the standard of care, was a joint tortfeasor, and ordered him to pay Lordan $1 million as pro rata contribution. Kurstin appealed, arguing the settlement released all claims including contribution and that the claim was an improper attempt by Blue to recover more than her damages. The appellate court affirmed, concluding the settlement language validly preserved the contribution claim and that District of Columbia law permits such reservation and assignment even when proceeds ultimately benefit the original plaintiff.
In Evans v. United States, the appellant was convicted of aggravated assault while armed after a jury trial in which he claimed self-defense in stabbing the victim during a street fight. He appealed on the ground that the trial court abused its discretion by denying a mistrial or curative instruction after the government referenced in its opening statement a false exculpatory statement by the defendant to police that was not later introduced at trial, which in turn prompted the defense to reference a related exculpatory statement it could not introduce. The District of Columbia Court of Appeals affirmed the conviction, holding that the trial court did not abuse its discretion because any error was harmless and the government's opening remark did not warrant the requested remedies. The court reasoned that the defense's reliance on the government's opening did not create unfair prejudice requiring a mistrial or special instruction, especially given the strength of the other evidence and the fact that the defendant did not testify.
The case concerned whether D.C. Code § 12-309 barred John Barnhardt’s tort claims against the District of Columbia for negligence and conversion after police destroyed property confiscated during his 2005 arrest. Barnhardt did not learn of the destruction until 2007 and sent notice to the Mayor in 2008, well after the six-month period measured from the date of destruction. The U.S. Court of Appeals for the D.C. Circuit certified the question to this court, which held that the statute does not bar the claims if the claimant lacked actual or constructive knowledge of the injury within six months. The court reasoned that the notice period presupposes the claimant’s awareness of injury or damage as a factual precondition, so the period does not begin to run until that awareness exists or reasonably should exist.
