Wilson v. District of Columbia Rental Housing Commission, 159 A.3d 1211 (2017)

Citation: Wilson v. District of Columbia Rental Housing Commission, 159 A.3d 1211 (2017)
Parent Document: Wilson v. District of Columbia Rental Housing Commission, 159 A.3d 1211 (2017)
Jurisdiction: DC (municipal)
Effective Date: 2017-05-18
Original Source: https://www.courtlistener.com/opinion/4392833/wilson-v-district-of-columbia-r... ↗

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We note that in United Dominion Mgmt. Co. v. District of Columbia Rental
Hous. Comm’n, this court held that it was error for the RHC to defer to the OAH
―[b]ecause the OAH is simply an all-purpose adjudicatory body, without a
particular subject-matter focus . . . .‖ 101 A.3d 426, 430–31 (D.C. 2014). In this
case, it is clear from the RHC‘s citation to these cases that it analyzed the issue de
novo rather than by deferring to the OAH ALJ‘s analysis. Thus, although the RHC
incorrectly stated its standard for reviewing OAH decisions as one requiring
―defer[ence] to a hearing examiner‘s decision so long as it flows rationally from
the facts and is supported by substantial evidence,‖ we are satisfied that the
misstatement was harmless error. See id. (reasoning that the RHC‘s erroneous
articulation of the applicable standard of review was inconsequential because the
agency‘s decision demonstrated it had not actually deferred to the OAH‘s
decision).
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