DTLD, LLC v. Power Station Limited Partnership; JPMorgan Chase Bank, Nat. Ass'n v. DTLD, LLC, et

District of Columbia Court of Appeals·Decided February 12, 2026·No. 24-CV-1163 & 24-CV-1173·Published

Opinion

Notice: This opinion is subject to formal revision before publication in the Atlantic and Maryland Reporters. Users are requested to notify the Clerk of the Court of any formal errors so that corrections may be made before the bound volumes go to press.

DISTRICT OF COLUMBIA COURT OF APPEALS No. 24-CV-1163

DTLD, LLC, et al., APPELLANTS, V.

POWER STATION LIMITED PARTNERSHIP, et al., APPELLEES.

&

No. 24-CV-1173

JPMORGAN CHASE BANK, N.A., APPELLANT, V.

DTLD, LLC, et al., APPELLEES.

Appeals from the Superior Court of the District of Columbia (2023-CAB-006784)

(Hon. Carl E. Ross, Motions Judge)

(Argued December 2, 2025 Decided February 12, 2026)

James T. Bacon for appellants DTLD, LLC, and Iraklion, LLC.

Eric S. Lammers, with whom Corey Zoldan was on the brief, for appellees Power Station Limited Partnership, Southern Building Associates, LLP, 15th and H Street Associates, LLP, and SJG Properties, LLC.

Jessica L. Farmer, with whom Zachary Lundgren was on the brief, for appellant JPMorgan Chase Bank, N.A.

Before EASTERLY and SHANKER, Associate Judges, and THOMPSON, Senior Judge.

THOMPSON, Senior Judge: The underlying issue in these consolidated appeals is the enforceability of a restrictive covenant that limits the use of an alleyway parcel of real property (the Property) formerly owned by appellee Power Station Limited Partnership (Power Station) and now owned by appellant DTLD, LLC (DTLD). When Power Station sold the Property in 2008, it included in the (recorded) deed a perpetual restrictive covenant that prohibited the Property from being used as a nightclub. Nearly fifteen years later, in 2023, appellant DTLD purchased the Property at an auction and subsequently leased it to appellant Iraklion, LLC (Iraklion), which has obtained a provisional alcoholic beverage license to operate a nightclub at the Property. In November 2023, Power Station and neighboring property owners filed a complaint for injunctive and declaratory relief to enforce the covenant and, after discovery, filed a motion for summary judgment. This appeal followed after the trial court entered summary judgment in favor of the plaintiffs and denied defendants’ cross-motion. Separately, JPMorgan Chase Bank, NA (JPMorgan), filed a motion to intervene in the litigation, which the trial court denied as moot. JPMorgan has appealed the denial of its intervention motion. For the foregoing reasons, we affirm the grant of summary judgment and the order dismissing the intervention motion as moot.

I.

The Property is located in a mixed-use zone within the District of Columbia’s Central Business District, where there is a mixture of office, retail, residential, entertainment, and other establishments, including other nightclubs. The Property address is 1412 I Street, N.W., but the Property is “located entirely within a network of public alleyways and has no frontage on any public street.” Vehicular access to the property is limited to a twenty-foot-wide alley running between 14th and 15th Streets, a ten-foot-wide alley running perpendicular to the previous alley, and a private driveway owned by JPMorgan that directly abuts the Property to the west. Patrons of the Property must enter and exit through the alleyways.

Most recently, the Property has been used as an office building. However, prior to 2008, a nightclub known as the Zei Club operated at the Property. During the period of its operation, there were fights and other violence in the alley outside the nightclub, including a 1998 near-fatal beating of a patron who had exited the Zei Club, which culminated in litigation that was resolved in 2009. 1

1 See generally Novak v. Capital Mgmt. & Dev. Corp., 570 F.3d 305 (D.C.

Cir. 2009); Novak v. Capital Mgmt. & Dev. Corp., 452 F.3d 902, 904 (D.C. Cir. 2006).

After the Zei Club closed, Power Station, which owned the Property at the time, was particularly concerned about the continued operation of a nightclub at the secluded, narrow-alleyway location, given the risks of loitering, violence, and crime and the challenges the location and patron lines present for access by emergency, delivery, and service vehicles. Power Station asserts that it rejected potential lessees that wanted to open another nightclub in the Property, believing that such a use would disrupt neighboring properties and cause the value of other surrounding properties it owns to decrease in value. Power Station ultimately agreed to sell the Property when the buyer agreed to a restriction that would preclude such a use. On or about January 15, 2008, Power Station transferred ownership of the Property by a Special Warranty Deed (the “2008 Deed”) containing a restrictive covenant that by its terms was “expressly made for the benefit of [g]rantor, and any successor in interest to the owners of real properties located in Square 220,” was expressly made “binding upon the [g]rantee and any successor in interest thereto,” and states in relevant part: “In no event shall there be conducted at the Property any nightclub or discotheque nor any other establishment which distributes or sells alcoholic beverages after midnight.”

The Property was sold again in 2015 to a subsequent buyer, which used it as an office space. In 2023, appellant DTLD, the current owner, purchased the Property at an auction. Bidders at the auction were informed about the restrictive covenant,

and DTLD admits it knew about it. After purchasing the Property, DTLD entered into an agreement with co-appellant Iraklion to operate a nightclub on the Property, and on July 28, 2023, the two entities submitted an application to the Alcoholic Beverage and Cannabis Board (the ABC Board or the Board) to transfer to the Property a Retailer’s Class CN license, which permits nude dancing. According to appellants, the proposed nightclub “is likely to feature” nude dancing and “Vegas- style” shows and would have a total occupancy of 1,200, seating for 675 patrons, and the following hours of operation: 8:00 AM to 3:00 AM on Sunday through Thursday; and 8:00 AM to 4:00 AM on Friday and Saturday.

The CN-license transfer application was the subject of much controversy. The ABC Board’s inquiry with respect to the license-transfer application was whether the transfer would have “an adverse impact on the peace, order, and quiet; residential parking and vehicular and pedestrian safety; and real property values of the area located within 1,200 feet of the establishment.” During a protest hearing that spanned two days, opponents of the license transfer expressed fears about the disruptive nature of a nightclub, the undesirable noise levels, the potential for conflicts between vehicles and pedestrians, the risk of crime or violence, and other adverse effects on property value and the general neighborhood. JPMorgan, which owns property in Square 220, participated in the hearing, explaining that the nightclub could adversely disrupt its own (next-door to 1412 I Street) operations

given its proximity to the Property and the possibility of nightclub patrons using JPMorgan’s private driveway. The ABC Board declined to consider evidence or arguments relating to the restrictive covenant, noting “whether or not there is or is not a covenant, that is not our issue to rule on at this juncture, so it is not relevant to the ABC Board to elicit testimony on that specific issue.” On June 5, 2024, the Board approved the transfer of a CN license to the Property, “credit[ing] Iraklion’s plans to promote public safety” and “to discourage violent incidents in and around the establishment” and finding that a nightclub is “eminently appropriate” for the location. 2

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DTLD, LLC v. Power Station Limited Partnership; JPMorgan Chase Bank, Nat. Ass'n v. DTLD, LLC, et, (D.C. 2026).

DTLD, LLC v. Power Station Limited Partnership; JPMorgan Chase Bank, Nat. Ass'n v. DTLD, LLC, et (DTLD, LLC v. Power Station Limited Partnership; JPMorgan Chase Bank, Nat. Ass'n v. DTLD, LLC, et) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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