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Harkins v. WIN Corp.

District of Columbia Court of Appeals

771 A.2d 1025 (2001)

Facts

WIN Corporation (WIN) (defendant) operated the Allen-Lee Hotel in the District of Columbia. Michael Harkins (plaintiff) occupied a room in the hotel. Harkins signed a hotel-registration card agreeing to a weekly charge of $85. WIN provided linen-and-cleaning service, as well as furniture for the room. Harkins fell behind in his weekly payments and was informed by the hotel manager that he would be evicted if he did not pay the money he owed. But Harkins remained delinquent in his payments. WIN changed the locks on Harkins’s room, thereby locking him out of the premises. Harkins subsequently brought suit against WIN for wrongful eviction. Harkins claimed that WIN was not permitted to evict him through self-help, that is, by repossessing the room without following the judicial eviction process. The trial court found that Harkins was a roomer, not a tenant, and that self-help was a permissible method to evict a roomer. The trial court granted summary judgment for WIN, and Harkins appealed.

Rule of Law

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Issue

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Holding and Reasoning (Pryor, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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