Mitchell v. Eastern Savings Bank, Fsb, 890 F. Supp. 2d 104

Mitchell had a written rental agreement with Pappas for upstairs unit plus one bedroom at 2507 33rd St. SE, Washington, DC, starting February 1, 1999.
In summer 2001, ESB foreclosed on the property and landlord-tenant actions were brought against Pappas and other tenants but not Mitchell.
Mitchell attempted to intervene in the Banks case in 2008; he sent letters asserting tenant rights in 2008–2009.
On February 9, 2009, ESB evicted Mitchell by removing belongings and changing locks, barring re-entry.
Mitchell alleges loss of heirlooms and tools and homelessness as a result of the eviction; he contends no notice to vacate was served.
ESB contends Mitchell became an at-will tenant and that an unlawful assignment to Banks terminated tenancy, potentially leaving Mitchell a squatter.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mitchell has a landlord-tenant relationship to support wrongful eviction.	Mitchell was a tenant under a lease and cannot be evicted without process.	Foreclosure rendered Mitchell an at-will tenant; unlawful assignment to Banks ended tenancy.	Question of tenancy status unresolved; claims survive for discovery.
Whether retaliatory eviction is cognizable under DC law.	Mitchell asserts retaliatory eviction due to asserted rights as a tenant.	DC does not recognize retaliatory eviction as a standalone claim.	Count II dismissed.
Whether breach of the implied covenant of quiet enjoyment lies where tenancy is questioned.	Even without a formal tenancy, eviction can breach quiet enjoyment.	Lack of a legitimate tenancy defeats this claim; no promised tenancy exists.	Count III denied dismissal; viable pending discovery.
Whether punitive damages can be pursued as an independent count.	Punitive damages may be sought as relief in wrongful eviction.	Punitive damages are not an independent cause of action.	Count IV dismissed as independent count; damages may be sought as relief.

Sarete, Inc. v. 1344 U St. Ltd. P’ship, 871 A.2d 480 (D.C. 2005) (recognizes possibility of wrongful eviction even without traditional tenancy)
Wilson v. Hart, 829 A.2d 511 (D.C. 2003) (addresses whether eviction can lie where occupancy is less than tenancy)
Hyde v. Brandler, 118 A.2d 398 (D.C. 1955) (implied covenant of quiet enjoyment precludes disturbance during tenancy)
Mendes v. Johnson, 389 A.2d 781 (D.C. 1978) (punitive damages available as relief in intentional torts)
Robinson v. Sarisky, 535 A.2d 901 (D.C. 1988) (punitive damages principles in DC torts framework)
Twyman v. Johnson, 655 A.2d 850 (D.C. 1995) (retaliatory eviction not recognized as independent cause of action)