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  • Brown v. Southall Realty Co.Brown v. Southall Realty Co.
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Brown v. Southall Realty Co.

District of Columbia Court of Appeals
237 A.2d 834 (1968)


District of Columbia Housing Regulations provide that rental properties shall be kept in a safe and sanitary manner. If not, the property may not be offered for rent. Southall Realty Co. (Southall) (plaintiff) owned a rental property in the District of Columbia, which had several housing code violations. These included an obstructed commode, a broken railing, and insufficient ceiling height in the basement. Without repairing the violations in question, Southall rented the property to Mrs. Brown (defendant). When Mrs. Brown fell behind on her rent payments, Southall brought an action against her. During the trial, Mrs. Brown agreed that she was in arrears on her rent, but argued that her lease was an illegal contract due to the living conditions of the apartment. The trial court ruled in favor of Southall. Mrs. Brown appealed to the District of Columbia Court of Appeals.

Rule of Law


Holding and Reasoning (Quinn, J.)

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