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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Carl v. Children's Hospital, 702 A.2d 159 (1997)

Citation
Carl v. Children's Hospital, 702 A.2d 159 (1997)
Parent Document
Carl v. Children's Hospital, 702 A.2d 159 (1997)
Jurisdiction
DC (municipal)
Effective Date
1997-09-23

Other Sections in This Document (617)

Full Text

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. See Edwards v. Lateef, 558 A.2d 1144 (D.C. 1989) (upholding retroactive application of Uniform Reciprocal Enforcement of Support Act to recover arrearages in child support that accrued before date URESA was amended to include ar-rearages within definition of duty to support; "statutes that create additional remedies, relate to the modes of procedure or confirm or clarify existing rights do not contravene the general proscription against the retrospective operation of legislation”) (citations and footnotes omitted); cf Duvall v. United States, 676 A.2d 448, 450-51 (D.C.1996) (upholding retroactive application of statute permitting deliberations in criminal case to proceed with only eleven jurors; “retroactive application of procedural statutes is proscribed” only if it "impairs the defendant's 'substantial rights’ ”) (citations omitted). . See Mendes, supra note 3, 389 A.2d at 788-89. . The four criteria are: