Catholic Charities--801 East Men's Shelter v. Byrd

CourtDistrict of Columbia Court of Appeals
DecidedMay 29, 2025
Docket24-AA-0750
StatusPublished

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Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 24-AA-0750

CATHOLIC CHARITIES – 801 EAST MEN’S SHELTER, PETITIONER,

V.

JAMAR BYRD, RESPONDENT.

On Petition for Review of a Decision of the Office of Administrative Hearings (2024-SHEL-00148)

(Argued April 9, 2025 Decided May 29, 2025)

Ian L. Slingsby, with whom Brian W. Stolarz was on the brief, for petitioner.

Laura D. Niday, with whom James E. Rocap III was on the brief, for appellee.

Before BLACKBURNE-RIGSBY, Chief Judge, and EASTERLY and MCLEESE, Associate Judges.

EASTERLY, Associate Judge: Shelters that provide housing to individuals

experiencing homelessness provide a critical service. Under the Homeless Services

Reform Act of 2005 (HSRA), D.C. Code §§ 4-751.01 to 4-756.07, such shelters may

terminate that housing only for cause and only by the statutorily mandated processes.

The HSRA authorizes two tracks for termination. Pursuant to section 4-754.36 and

section 4-754.33(c), a shelter may terminate services to a client for an array of 2

enumerated reasons with fifteen days’ notice, thereby giving the client time both to

challenge the termination, see id. § 4-754.41(d), and, presumably, to try to find other

housing. Alternatively, pursuant to section 4-754.38, a shelter may terminate

services on an “emergency” basis without any advance notice to a client. Given its

harsh result, emergency termination is permitted in limited situations; a shelter may

only exercise this authority where the client “presents an imminent threat to the

health or safety of the client or any other person on a provider’s premises,” taking

into account “the severity of the act or acts leading to the imminent threat.” Id.

§ 4-754.38(a).

In this case, petitioner Catholic Charities – 801 East Men’s Shelter (Catholic

Charities) appeals from the reversal of its emergency termination of respondent

Jamar Byrd by the Office of Administrative Hearings (OAH). Catholic Charities

argues that the OAH administrative law judge (ALJ) incorrectly “restricted” its

analysis of Mr. Byrd’s conduct and elevated the “severity” standard beyond that

which is required by D.C. Code § 4-754.38(a). But we conclude that the ALJ

correctly understood and applied the law and that Catholic Charities’ argument to

the contrary is based on a mischaracterization of the ALJ’s ruling and the record

evidence. We reject as unpreserved Catholic Charities’ argument that the ALJ

wrongly precluded it from presenting evidence of Mr. Byrd’s alleged history of 3

violent acts. And we reject as meritless Catholic Charities’ argument that the ALJ

wrongly discredited its witness. Accordingly, we affirm.

I. Procedural History and Facts

Catholic Charities’ effort to remove Mr. Byrd from the 801 East Men’s

Shelter, where he was a participant in the “work-bed program,” began well before

the shelter issued the 2024 emergency termination notice at issue in this case. 1 In

October 2023, Catholic Charities issued a non-emergency notice of termination

under D.C. Code § 4-754.36, which the ALJ reversed in January 2024 after Mr. Byrd

requested a hearing to challenge the termination and Catholic Charities failed to

comply with the ALJ’s directive to file a status report. On March 14, 2024, Catholic

Charities removed Mr. Byrd from the shelter, without notice, forcing Mr. Byrd to

sleep outside for several days. On March 21, 2024, the ALJ instructed Catholic

Charities that termination without the requisite fifteen-day notice, see D.C. Code

§ 4-754.33(c), was not permitted, and, on March 22, shelter staff emailed Mr. Byrd

advising him that he was allowed to return to the shelter. Also on March 22, Catholic

Charities issued a new, non-emergency notice of termination based on allegations

that Mr. Byrd “g[ot] physical” with security staff at the shelter when they attempted

1 The same ALJ appears to have handled Mr. Byrd’s challenges to two prior attempts by Catholic Charities to remove him from the 801 East Men’s Shelter. The ALJ took “official notice” of its orders disposing of these prior cases. 4

to unlawfully remove him on March 14. The effective termination date of the March

22 notice was April 6, 2024. But when Mr. Byrd returned to the shelter on the

evening of March 22, security staff again attempted to remove him, resulting in a

confrontation in the shelter cafeteria.

Later that evening, Catholic Charities filed a Notice of Emergency

Termination pursuant to D.C. Code § 4-754.38, alleging that it was entitled to

immediately terminate services to Mr. Byrd because he posed an “imminent threat

to the health and safety of [him]self or any other person” at the shelter. The notice

specifically alleged that, after refusing to accept service of the non-emergency

termination notice when he returned to the shelter on March 22, Mr. Byrd had

“pushed” a security officer 2 (Major Flippen), had been generally “non-compliant”

and “hostile,” and had threatened to kill officers and/or shelter staff. Mr. Byrd

challenged the emergency termination, and the case proceeded to an evidentiary

hearing in June 2024. At the hearing, Catholic Charities presented testimony from

Jonetta Carpenter, a program supervisor at the shelter, and Mr. Byrd testified on his

own behalf.

2 Catholic Charities did not present any evidence as to who employs the security officers at the 801 East Men’s Shelter or what their authorized powers are. Record documents refer to them as both “SPOs” and “USP Officer[s]” without further elaboration. 5

Ms. Carpenter testified that Mr. Byrd entered the shelter on the evening of

March 22, 2024, and “walk[ed] past the front desk.” Ms. Carpenter “tried to stop

[him] to give him” the non-emergency termination notice issued that day, 3 but

Mr. Byrd told her “catch me if you can” and proceeded to the cafeteria. At that

point, Ms. Carpenter testified, she asked security to “go down” to the cafeteria and

“bring Mr. Byrd back up.” Ms. Carpenter did not immediately accompany the

security officers and thus was not in the cafeteria when they first confronted

Mr. Byrd. Apparently relying in part on what she observed in video footage of the

incident, she testified that after “[s]ecurity went down [to the cafeteria] to try to get

Mr. Byrd[,] [h]e became very, very hostile, started threatening, pushing, shoving all

officers on duty.” She then read directly from an incident report, which stated that

3 During the evidentiary hearing, counsel for Catholic Charities introduced as an exhibit the original, non-emergency, March 22, 2024, notice that Ms. Carpenter tried to serve. Counsel did not ask for, and Ms.

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