Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Citation
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Parent Document
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Jurisdiction
- DC (municipal)
- Effective Date
- 2005-03-24
Other Sections in This Document (33)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
- Miller v. District of Columbia Rental Housing Commission, 870 A.2d 556 (2005)
Full Text
1,272 charsD.C.Code § 42-3509.01 provides penalties for violations of the Rental Housing Act depending on the nature of the violation but also on the state of mind of the wrongdoer. Thus, § 42-3509.01(a) subjects a person who "knowingly" commits certain violations having to do with rent charges or provision of services to the penalty of return of excess rent (which may be trebled) or a roll back of rent charged. In Quality Mgmt., Inc. v. District of Columbia Rental Hous. Comm'n, 505 A.2d 73 (D.C.1986), this court sustained as reasonable the RHC's interpretation of "knowingly" in that section to mean "only a knowledge of the essential facts bringing [the person's] conduct within the reach of [the penalty provision]." Id. at 75. Because "the law presumes knowledge of the legal consequences arising from performance of the prohibited conduct," the section does not require "actual knowledge of the unlawfulness of the [prohibited] act or omission." Id.; see also Webb v. District of Columbia Rental Hous. Comm'n, 505 A.2d 467, 469-70 (D.C.1986). This interpretation of "knowingly," we added in Quality Mgmt., is further supported by the need "to draw some independent meaning from the word `willfully' as used in another context in [§ 42-2509.01(b)]." Id. (footnote omitted).