Edwards v. Habib

397 F.2d 687 (1968)

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Edwards v. Habib

United States Court of Appeals for the District of Columbia Circuit
397 F.2d 687 (1968)

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Facts

Yvonne Edwards (defendant) rented residential property from Nathan Habib (plaintiff) under a month-to-month lease. When Habib failed to remedy housing-code violations, Edwards reported the violations to the Department of Licenses and Inspections (department). A department inspection discovered more than 40 housing-code violations. The department ordered Habib to rectify them. Habib then gave Edwards 30 days’ notice to vacate the property, in compliance with the District of Columbia Code (DC Code). Habib sued Edwards for possession of the property and obtained a default judgment against her. Edwards moved to reopen the judgment, arguing, among other things, that Habib should not be permitted to evict her in retaliation for reporting violations. The trial court reasoned that the DC Code allowed a landlord to evict a month-to-month tenant without reason, rendering evidence of retaliatory motive irrelevant. The court directed a verdict for Habib. The District of Columbia Court of Appeals affirmed, and Edwards appealed to the United States Court of Appeals for the District of Columbia Circuit.

Rule of Law

Issue

Holding and Reasoning (Wright, J.)

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Housing Law
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