Brown v. District of Columbia Housing Authority, Civil Action No. 2016-1771

Plaintiff, proceeding pro se, filed a complaint alleging DCHA and a private manager maintained unsafe, unhealthy Section 8 housing in D.C., violating the Fair Housing Act, ADA, Rehabilitation Act, and DC law.
He sought a permanent injunction and declaratory relief to remedy systemic health, safety, sanitation, and staffing problems affecting tenants.
The District of Columbia Housing Authority (DCHA) moved to dismiss for lack of standing and failure to state a claim; the court reviewed jurisdictional defects of standing and mootness.
Plaintiff conceded he sought relief on behalf of unnamed tenants and cited Ashton for next-friend authority; the court found he did not meet next-friend requirements under Whitmore and Rule 17.
Plaintiff no longer lives in D.C. (moved to New York), and the court concluded his claims for equitable relief were moot as he is no longer a DCHA tenant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to seek injunctive relief on behalf of other tenants	Plaintiff argued he could sue as "next friend" for other tenants (citing Ashton)	DCHA argued plaintiff lacked personal injury and was seeking relief for unnamed tenants, so no standing	Dismissed: plaintiff lacked standing and did not satisfy next-friend requirements
Mootness of equitable/declaratory claims	Plaintiff did not dispute moving; implicitly sought systemic relief	DCHA argued plaintiff’s relocation mooted his request for injunction/declaratory relief against DCHA-managed housing	Dismissed as moot: plaintiff’s relocation to New York ended his stake in DCHA housing; declaratory relief requires a live controversy

Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts have limited subject-matter jurisdiction)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury in fact, causation, and redressability)
Friends of the Earth, Inc. v. Laidlaw Environmental Services, 528 U.S. 167 (2000) (standing elements discussed and applied)
Lyons v. City of Los Angeles, 461 U.S. 95 (1983) (requirement of concrete, particularized injury for injunctive relief)
Whitmore v. Arkansas, 495 U.S. 149 (1990) (requirements for "next friend" standing)
Haase v. Sessions, 835 F.2d 902 (D.C. Cir. 1987) (court looks to complaint to determine jurisdiction)
Sierra Club v. Jackson, 648 F.3d 848 (D.C. Cir. 2011) (federal courts cannot decide moot questions)
City of Houston v. Department of Housing & Urban Development, 24 F.3d 1421 (D.C. Cir. 1994) (declaratory relief presupposes a remediable right)
Simpkins v. D.C. Government, 108 F.3d 366 (D.C. Cir. 1997) (court must stop when lacking subject-matter jurisdiction)