Kitchings v. DC Rental Housing Commission [PDF], 588 A.2nd 263 (1991) - Where first increase was improper and second increase builds upon first increase, amount of second increase is also improper, but that does not mean that rental increase could never be imposed, even if properly calculated.

Nwanko v. DC Rental Housing Commission [PDF], 542 A.2nd 827 (1988) – Landlord’s failure to give ten-day notification of self-certification of abatement of housing code violations did not invalidate subsequent rent increase taken by landlord absent showing by tenants that property was not in substantial compliance with housing code.