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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Temple v. District of Columbia Rental Housing Commission, 536 A.2d 1024 (1987)

Citation
Temple v. District of Columbia Rental Housing Commission, 536 A.2d 1024 (1987)
Parent Document
Temple v. District of Columbia Rental Housing Commission, 536 A.2d 1024 (1987)
Jurisdiction
DC (municipal)
Effective Date
1987-12-01

Other Sections in This Document (118)

Full Text

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Nor does this court's decision in Frenkel v. District of Columbia Rental Accommodations Commission, 432 A.2d 1226 (D.C.1981), compel that we affirm the agency's use of 1973 as the base year. The petitions in Frenkel were filed under the 1975 Act when the small landlord exemption had undergone numerous transitions. Thus, that decision has relevance only to petitions filed under that Act. Moreover, Frenk-el contains some language which must be read in context. Thus, regardless of the language in Frenkel concerning the procedural requirements necessary for perfecting a claim of exemption under the 1975 Act and its amendments, the holding in Frenkel is based on the landlord’s substantive disqualification for exemption. The landlord rented not only a single-family dwelling but also a multi-unit, multi-story apartment building, and thus was clearly not entitled to an exemption.