ROSANNE L. WOODROOF v. JOSEPH F. CUNNINGHAM, 147 A.3d 777

Background

Woodroof retained Cunningham in 2008 for D.C. litigation and signed a retainer containing an Arbitration Agreement covering “any dispute as to legal malpractice.”
After settlement of the underlying suit, a fee dispute arose; Cunningham later sued Woodroof in Virginia and obtained a default judgment for unpaid fees, which Cunningham sought to register and enforce in D.C.
Woodroof sued Cunningham for legal malpractice in D.C. Superior Court in 2013; Cunningham moved to stay and compel arbitration and the trial court granted the motion.
Woodroof appealed the order compelling arbitration; Cunningham argued the D.C. Court of Appeals lacked jurisdiction to hear an appeal from an order granting arbitration under the Home Rule Act.
The Court of Appeals held it had jurisdiction under the RUAA (D.C. Code §16‑4427(a)(1)), concluded the arbitration clause covered Woodroof’s malpractice claim, and rejected Woodroof’s adhesion/unconscionability and waiver arguments.
Separately, the Superior Court granted Woodroof relief from the Virginia judgment on grounds that the Arlington court lacked subject‑matter jurisdiction due to D.C. Bar Rule XIII; both parties’ motions for contempt/sanctions were denied as the February 2013 order was ambiguous.

Issues

Issue	Woodroof's Argument	Cunningham's Argument	Held
Whether D.C. Court of Appeals has jurisdiction to hear appeal from an order granting arbitration under RUAA given Home Rule Act limits	§16‑4427(a)(1) is invalid as exceeding Council authority under the Home Rule Act	RUAA authorizes appeals from orders granting arbitration; appellate jurisdiction is proper	Court holds RUAA §16‑4427(a)(1) does not violate Home Rule Act and appellate jurisdiction exists
Whether the malpractice claim is arbitrable under the Arbitration Agreement	Agreement is ambiguous or selectively enforced; malpractice claim not subject to arbitration	Agreement explicitly covers legal malpractice; dispute fits clause	Arbitration clause is susceptible to covering the malpractice claim; arbitrability decided for arbitration
Whether the arbitration agreement is an unenforceable consumer adhesion/unconscionable contract	Agreement is adhesionary and unconscionable; Woodroof had no meaningful choice	Agreement was negotiated with counsel present; no evidence of lack of choice or inability to obtain alternative counsel	Appellant failed to prove adhesive/unconscionable contract; agreement enforceable
Whether trial court erred in denying motions for contempt/sanctions re: enforcement of Virginia judgment	Cunningham’s $75,000 demand to lift lien enforced the foreign judgment violating the court’s prior order; contempt warranted	Woodroof’s contempt and sanctions motions were frivolous or improper	Denials affirmed: order language ambiguous; no clear and convincing proof of contempt; motions for sanctions not an abuse of discretion

Key Cases Cited

Brandon v. Hines, 439 A.2d 496 (D.C. 1981) (distinguishing appealability of orders denying vs granting stays pending arbitration)
Koczak v. Am. Fed’n of Gov’t Emps., 439 A.2d 478 (D.C. 1981) (analyzing which arbitration‑related orders are "deemed final")
Stuart v. Walker, 6 A.3d 1215 (D.C. 2010) (discussing Home Rule limits on Council authority; opinion later vacated but cited for analysis)
Andrew v. Am. Imp. Ctr., 110 A.3d 626 (D.C. 2015) (holding orders compelling arbitration of adhesion‑contract consumer disputes may be appealable)
Haynes v. Kuder, 591 A.2d 1286 (D.C. 1991) (standard for court review of arbitrability)
Masurovsky v. Green, 687 A.2d 198 (D.C. 1997) (presumption to construe ambiguities in arbitration clauses in favor of arbitration)
Woodland Ltd. P’ship v. Wulff, 868 A.2d 860 (D.C. 2005) (waiver of arbitration is presumptively for the arbitrator; ambiguity resolved against waiver)
Dimond v. District of Columbia, 792 F.2d 179 (D.C. Cir. 1986) (holding substantive statutory changes that incidentally affect court caseloads do not necessarily alter court jurisdiction)