Snowden v. Benning Heights Cooperative, Inc.

557 A.2d 151, 1989 D.C. App. LEXIS 59, 1989 WL 34541
CourtDistrict of Columbia Court of Appeals
DecidedApril 12, 1989
Docket87-1204
StatusPublished
Cited by6 cases

This text of 557 A.2d 151 (Snowden v. Benning Heights Cooperative, 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.

Bluebook
Snowden v. Benning Heights Cooperative, Inc., 557 A.2d 151, 1989 D.C. App. LEXIS 59, 1989 WL 34541 (D.C. 1989).

Opinion

ROGERS, Chief Judge:

The issue in this appeal is whether a foreign cooperative association owning premises in the District of Columbia may terminate membership in the association for failure to pay monthly carrying charges without a vote of the membership pursuant to D.C.Code § 29-1130 (1981). The trial court ruled that, in accordance with a 1984 amendment, D.C.Code § 29-1141 (1988 Supp.), the termination of appellants’ membership without a vote of the membership was lawful because the cooperative association followed the procedures authorized by the laws of the state in which it is incorporated. The trial court also ruled that the notice provisions of the District of Columbia Rental Housing Act of 1985, D.C.Code § 45-2551(a) (1986 Repl.), do not apply to the eviction of a member from a cooperative association. We affirm.

I

Appellee, Benning Heights Cooperative, Inc. (BHC or the Cooperative), is a membership housing cooperative incorporated under the laws of the State of Maryland and the owner of premises located in the District of Columbia. Appellants, Lillian and Ronald Snowden, were members of the Cooperative and held a proprietary lease in *152 the Cooperative at the District of Columbia premises.

Appellants were served with a notice of termination of their membership on April 9, 1986, pursuant to a vote of BHC’s board of directors (the Board). The notice alleged that appellants were in arrears of payment of their share of the monthly mortgage payment and operating costs to the Cooperative, and gave appellants ten days to cure the default.

On April 21, 1986, appellants proposed a payment schedule for the arrearage, which the Board accepted. Appellants failed, however, to make payments according to the schedule, and on June 17, 1986, BHC instituted an action for possession. The trial court denied BHC’s motion for summary judgment on the ground that BHC had failed to serve appellants with the thirty-day notice to quit required by D.C.Code § 45-1403 (1986 Repl.) for tenants-at-will.

BHC thereafter served appellants with notice under § 45-1403, and upon the expiration of the thirty-day period, BHC instituted another action seeking possession. Appellants contested the action, arguing that BHC had not legally terminated appellants’ membership in the Cooperative in accordance with D.C.Code § 29-1130 (1981), 1 and that appellants were not served proper notice under D.C.Code § 45-2551 (1986 Repl.). 2 The trial court ruled that D.C.Code § 29-1141 (1988 Supp.), 3 controlled BHC’s right, under Maryland law, to terminate appellants’ membership in the Cooperative pursuant to a vote of the Board as set forth in the Occupancy Agreement, rather than by a vote of the membership under D.C.Code § 29-1130, and that the Cooperative was not subject to the Rental Housing Act provisions. Appellants contend the trial court erred in both rulings.

II

A.

In 1984 the Council of the District of Columbia amended the District of Columbia Cooperative Association Act to provide that a foreign cooperative “shall govern itself in accordance with its bylaws and the laws of the state wherein it is organized.” See note 3, supra. The words of the 1984 amendment appear unambiguous, and the legislative history indicates the clarity of the D.C. Council’s intent. 4 The Council was concerned with ensuring the economic health of cooperatives, recognizing that the requirement for expulsion only by a membership vote presented practical difficulties. 5 The sponsor of the amendment noted, for example, that because Dis *153 trict of Columbia law prohibits proxy voting, a foreign cooperative would not be able to expel a member for “nonpayment of cooperative fees or for any other serious offense against the cooperative” since a quorum to vote on the expulsion could be impossible to achieve without proxies. 6 The intent of the amendment, as declared by its sponsor, therefore, was to “allow the [cooperative [association to govern itself in accordance with its bylaws and the laws of the state within which it was organized.” Thus the main thrust of the amendment was to have District of Columbia law “recognize as valid how foreign corporations are authorized to act under the [law of the] outside state.” 7 Responding to one Council member’s concern that the amendment was inconsistent with other District of Columbia laws, the sponsor of the amendment emphasized that the amendment was designed simply to enable cooperatives to operate in a “financially healthy environment.” 8

The trial court found that the intent of the 1984 amendment was to authorize foreign cooperatives to function in accordance with the laws of the state in which they are incorporated, as opposed to District of Columbia law, with regard to governance issues. Appellants claim this was error because the D.C. Council did not realize the effect that the amendment would have and that the amendment was intended to change only the way foreign cooperatives vote, not to authorize termination without membership voting, as may be allowed in other states. We disagree with appellants’ interpretation of the Council’s intent. The amendment’s sponsor recognized that the 1984 amendment might affect the treatment of foreign cooperatives owning premises in the District of Columbia. 9 Rather than limiting the amendment to changing the voting procedures of foreign cooperatives, the Council members acknowledged repeatedly that the amendment’s broader purpose was to allow foreign cooperatives to operate under the laws of the state in which they are incorporated.

Appellants also maintain that the amendment so interpreted would make every *154 member of a foreign cooperative residing in premises located in the District of Columbia subject to another state’s laws. Of course cooperative members then would be treated no differently than are shareholders of foreign corporations, who also are subject to another state’s laws.

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Bluebook (online)
557 A.2d 151, 1989 D.C. App. LEXIS 59, 1989 WL 34541, Counsel Stack Legal Research, https://law.counselstack.com/opinion/snowden-v-benning-heights-cooperative-inc-dc-1989.