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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Section 11-721

Citation
Section 11-721
Parent Document
Brown v. Pearson (2020)
Jurisdiction
DC (municipal)
Effective Date
2020-04-02

Other Sections in This Document (332)

Full Text

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48
          Stets v. Featherstone, 754 A.2d 292, 296 (D.C. 2000). We have rejected
narrowly defining the landlord’s “need” as the “risk [of] foreclosure or a net
operating loss without a protective order,” Graham, 19 A.3d at 365-66, although a
landlord’s “exigency” remains an important factor, id. at 367; see also Davis, 456
A.2d at 827 (plurality opinion) (“[T]he Constitution expressly protects against
confiscation of private property or the income therefrom.” (quoting Lindsey, 405
U.S. at 74)).
      49
           Graham, 19 A.3d at 366.
      50
           Id.
      51
           But see footnote 35, supra.
      52
          Ms. Brown claims that the court also abused its discretion when it denied
her motion for sanctions. Our jurisdiction to reach that question is doubtful at best.
Cf. In re Estate of Murrell, 878 A.2d 462, 465 (D.C. 2005) (“Because Wallace was
                                         26 So ordered.