DISTRICT OF COLUMBIA v. MELVERN REID
104 A.3d 859
| D.C. | 2014Background
- In winter 2013–2014 DHS placed families in partitioned areas of two recreation centers (cots behind portable partitions) after apartment-style shelters and available hotel rooms were exhausted.
- Families alleged the communal placements lacked privacy, security, sanitary bathing/restroom access, and posed psychological risks to children; they sued under the Homeless Services Reform Act (HSRA).
- The Superior Court granted a TRO and then a preliminary injunction requiring the District to place the plaintiff families in apartment-style shelter or, if none available, private rooms on nights when actual or forecasted temperature (including wind chill) falls below 32°F.
- The District appealed, arguing the HSRA’s private right to sue for “shelter in severe weather conditions” does not permit suing to enforce the apartment-style/private-room requirement, and that the court should have considered impossibility of compliance and excluded expert testimony.
- The D.C. Court of Appeals reviewed statutory interpretation de novo, deferred to trial fact findings, and affirmed the preliminary injunction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether HSRA’s § 4-755.01(a) private right to sue for “shelter in severe weather conditions” allows families to enforce the statute’s apartment-style/private-room requirement | Families: § 4-755.01(a) incorporates mandatory Continuum-of-Care provisions (§ 4-753.01(d)); thus severe-weather entitlement includes apartment-style shelter (or private rooms if none available) | District: The right to sue for severe-weather shelter only authorizes minimal shelter (a building/roof), not the full apartment-style/private-room mandate | Held: The right to sue for severe-weather shelter includes the statutory protection for families to obtain apartment-style shelter, or private rooms if none available; injunction likely to succeed on merits |
| Whether trial court must evaluate defendant’s asserted impossibility to comply before granting injunctive relief | Families: Standard four-factor injunction test controls; impossibility is considered within equities/public-interest factors, not a separate required inquiry | District: Court should require consideration of impossibility as part of preliminary-injunction analysis | Held: No separate impossibility requirement; trial court did not abuse discretion where District failed to show literal impossibility of compliance |
| Admissibility of plaintiffs’ expert testimony on harm to children (qualification and basis) | Families: Expert (advanced doctoral training, supervised clinical experience with homeless youth) was qualified and may rely on courtroom testimony and standard professional sources | District: Expert lacked license, local observation, and based opinions only on plaintiffs’ testimony — not qualified and opinion was speculative | Held: Trial court did not abuse discretion in qualifying and admitting the expert; experience and typical sources suffice |
| Whether evidence established likelihood of irreparable harm to justify preliminary injunction | Families: Credible firsthand testimony about recreation-center conditions plus expert opinion showed likely psychological and other harms to children; statutory violation itself supports irreparable-harm finding | District: Evidence insufficient; expert opinions speculative | Held: Evidence (witness testimony, expert opinion, and statutory purpose) sufficiently supported irreparable-harm finding; injunction appropriate |
Key Cases Cited
- United States v. Brown, 333 U.S. 18 (Sup. Ct.) (rejecting constructions producing absurd results)
- Baltimore v. District of Columbia, 10 A.3d 1141 (D.C. 2011) (interpreting HSRA entitlements and consulting Continuum-of-Care provisions)
- Wieck v. Sterenbuch, 350 A.2d 384 (D.C. 1976) (four-factor preliminary injunction framework)
- District of Columbia v. Group Ins. Admin., 633 A.2d 2 (D.C. 1993) (deference to trial court on injunction findings except legal questions)
- District of Columbia v. Sierra Club, 670 A.2d 354 (D.C. 1996) (de novo review for statutory interpretation questions)
- In re Estate of Reilly, 933 A.2d 834 (D.C. 2007) (preliminary injunction may issue on high probability of success + some injury or vice versa)
- Cobell v. Norton, 428 F.3d 1070 (D.C. Cir. 2005) (extraordinary impossibility of compliance may require injunctive modification)