Foster House Tenants Assoc. v. New Bethel Baptist Church Housing Corp. Inc.

CourtDistrict of Columbia Court of Appeals
DecidedMay 26, 2022
Docket20-CV-635
StatusPublished

This text of Foster House Tenants Assoc. v. New Bethel Baptist Church Housing Corp. Inc. (Foster House Tenants Assoc. v. New Bethel Baptist Church Housing Corp. Inc.) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Foster House Tenants Assoc. v. New Bethel Baptist Church Housing Corp. Inc., (D.C. 2022).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 20-CV-635

FOSTER HOUSE TENANTS ASSOCIATION, APPELLANT,

V.

NEW BETHEL BAPTIST CHURCH HOUSING CORPORATION, INC., ET AL., APPELLEES.

Appeal from the Superior Court of the District of Columbia (CAR-5760-19)

(Hon. Jason Park, Trial Judge)

(Argued April 26, 2022 Decided May 26, 2022)

Eric J. Konopka, with whom Brent T. Murphy, of the Bar of the State of Virginia, pro hac vice, by special leave of the court, and Matthew J. Moore and Christopher J. Brown were on the brief, for appellant.

Gwynne L. Booth, with whom Richard W. Luchs and Vincent Mark J. Policy were on the brief, for appellees.

Before EASTERLY, MCLEESE, and DEAHL, Associate Judges.

EASTERLY, Associate Judge: Foster House Tenants Association appeals the

Superior Court’s grant of summary judgment for defendants New Bethel Baptist

Church Housing Corporation, Inc. and Evergreen 801 RI Apartments LLC. Because 2

we conclude that ruling was legally and factually unsupported, we reverse and

remand for the parties to proceed with discovery.

New Bethel and Evergreen entered into a 104-year ground lease for Square

0396N, Lot 0006, a plot of land on which the Foster House Apartments complex

stands. The parties—whose relationship is opaque, see infra—agreed that Evergreen

would pay both an upfront fee of $2,150,000, as well as gradually escalating rent

beginning six years into the lease. In return, Evergreen would receive, first, a

leasehold in the entire lot excluding Foster House 1, and second, a right to obtain a

leasehold in that additional property for the remainder of the 104-year term, upon

the occurrence of certain contingent conditions (the nature and probability of which

are not clear, see infra).

The Tenants Association sued, alleging that the lease constituted a sale to a

third party in violation of the District’s Tenant Opportunity to Purchase Act (TOPA),

D.C. Code § 42-3404.01 et seq. (2020 Repl. & 2021 Supp.). Several months later,

New Bethel extended a TOPA offer of sale to the Tenants and filed a motion to

It appears to us—as it did to the trial court—that this initial leasehold interest 1

was to include the land underneath Foster House. New Bethel and Evergreen contend that the initial leasehold interest was to exclude the land underneath Foster House, but provide no support for this view other than some conclusory declarations. 3

dismiss or motion for summary judgment on the ground that the offer mooted the

Tenants’ claim. As well as opposing the motion, the Tenants moved for summary

judgment on the merits and requested rescission of the ground lease. After providing

notice to the parties, the trial court treated the defendants’ subsequent opposition to

the Tenants’ motion as a cross-motion for summary judgment on the merits. So

construing, the court granted both of the defendants’ motions for summary

judgment, ruling that the lease did not constitute a sale under TOPA and that “the

equities here [did] not favor rescission of the ground lease.” 2

Under TOPA as revised over the years, a “sale” of property is a term of art

that extends beyond the immediate, absolute transfer of title. The statute’s definition

of “the terms ‘sell’ or ‘sale’ include[s], but [is] not limited to, the execution of any

agreement pursuant to which the owner of the housing accommodation agrees to

some, but not all, of the following:”

(1) Relinquish[ing] possession of the property;

(2) Extend[ing] an option to purchase the property for a sum certain at the end of the assignment, lease, or encumbrance and provid[ing] that a portion of the

2 Although the trial court’s order contains a “mootness” heading indicating it was addressing New Bethel and Evergreen’s claims that the Tenants’ TOPA claim was moot by virtue of New Bethel’s post-filing TOPA offer of sale, the court did not engage in any mootness analysis. 4

payments received pursuant to the agreement is to be applied to the purchase price;

(3) Assign[ing] all rights and interests in all contracts that relate to the property;

(4) Requir[ing] that the costs of all taxes and other government charges assessed and levied against the property during the term of the agreement are to be paid by the lessee either directly or through a surcharge paid to the owner;

(5) Extend[ing] an option to purchase an ownership interest in the property, which may be exercised at any time after execution of the agreement but shall be exercised before the expiration of the agreement; and

(6) Requir[ing] the assignee or lessee to maintain personal injury and property damage liability insurance on the property that names the owner as the additional insured.

D.C. Code § 42-3404.02(b). Further underscoring that function, not form, is

paramount, § 42-3405.03b(b) states that the rights created under TOPA “shall be

determined by examining the substance of the transaction or series of transactions”

that is alleged to constitute a sale.

Insofar as the trial court ruled that something less than an absolute transfer of

title is not a “sale” under § 42-3404.02(a), it was incorrect. As discussed above,

“sell” and “sale” are defined in § 42-3404.02(b) and those definitions apply broadly 5

to all of “subchapters IV and V of this [C]hapter” 3—in other words, the entirety of

TOPA, codified as §§ 42-3404.01 to .14, and more. Any prior treatment of

§ 42-3404.02(b) as providing a secondary definition of “sale” 4 predates and cannot

survive the 2005 amendments to TOPA.

But the court’s ruling terminating this case not only evinced a

misunderstanding of the law: it was also premised on an incomplete set of facts that

did not permit a thorough analysis of the substance of the transaction at issue. Under

the ground lease, “[i]f, at any time during the Term, [Foster House] become[s] vacant

and unoccupied by tenants then, upon written notice from [Evergreen] to [New

Bethel], [Foster House] shall thereafter become part of the Premises and shall

thereafter be subject to all of the terms and conditions of this Lease . . . .” That the

ground lease transfers only a leasehold interest rather than absolute title does not

prevent it from constituting a sale under TOPA, see § 42-3404.02(c) (including

master leases within the definition of a sale), nor does the fact that Evergreen’s

interest in Foster House is contingent upon a future event. See § 42-3404.02(b)(2),

3 Referring to Chapter 34, “Rental Housing, Conversion, and Sale.” 4 See, e.g., Gomez v. Indep. Mgmt. of Del. Inc., 967 A.2d 1276, 1282 (D.C. 2009) (drawing on the definition of “sale” in W. End Tenants Ass’n v. George Washington Univ., 640 A.2d 718 (D.C. 1994), to analyze the 2001 version of TOPA). 6

(b)(5). But the likelihood of that future event and the power the parties have to bring

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