Monday, June 11, 2012
Johnson v. DC Rental Housing Commission
642 A.2nd 135 (1994)
In reviewing decision by Rental Accommodations and Conversion Division (RACD) voiding rent increases, Rental Housing Commission (RHC) improperly determined that landlord was exempt from rent increase restrictions of Rental Housing Act under res judicata principles; RHC improperly took official notice of entire RACD file in concluding that tenant petitioner had been party to prior proceeding, and prior RACD decision was insufficient to prove RACD decision was insufficient to prove that tenant had been party to prior proceeding.