Samuels v. Southern Hills Limited Partnership, Civil Action No. 2016-0873

Background

Plaintiff Jakayarn Samuels sustained burns when unattended oil on her stovetop began smoking and then ignited as she moved the pot; her hair and clothing caught fire but she extinguished the flames.
Samuels sued her landlord, Southern Hills Limited Partnership, asserting negligence and breach of lease for failing to provide/maintain a working smoke detector, a visible and accessible fire extinguisher, and a functioning “Firestop” device above the stove.
Defendant moved for summary judgment; it conceded for purposes of the motion that (viewed favorably to Plaintiff) no working smoke detector and no visible extinguisher were provided, but disputed causation and fault.
The Court denied summary judgment as to claims based on the missing/defective smoke detector and absent fire extinguisher, finding triable issues of fact about whether those deficiencies proximately caused the injuries.
The Court granted summary judgment for Defendant on the claim based on the Firestop, because Plaintiff produced no affirmative evidence or expert opinion showing the Firestop was defective or failed to operate.
The Court applied the same rulings to the parallel breach-of-contract claim (tenant may proceed on smoke detector and extinguisher theories but not on the Firestop theory) and rejected Defendant’s attempt to shift blame to Plaintiff for not reporting defects.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether contributory negligence bars recovery for landlord's statutory violations	Samuels: statutory violations by landlord make contributory negligence unavailable as a complete defense	Southern Hills: Samuels’ leaving the pot unattended and delayed response absolve landlord	Held: Contributory negligence cannot defeat liability for violations of D.C. fire-safety statutes at summary judgment stage (landlord conceded statutory violations exist when facts construed for Plaintiff).
Whether absence/failure of smoke detector/fire extinguisher proximately caused injuries	Samuels: absent/dysfunctional smoke alarm and no visible extinguisher likely delayed notice/response and caused injuries	Southern Hills: daughter noticed smoke; alarm/extinguisher would not have given earlier notice or changed outcome	Held: Genuine disputes of material fact exist (including expert testimony that an alarm likely would have given earlier notice), so summary judgment denied on these theories.
Whether Firestop malfunction supports liability	Samuels: Firestop may have failed to operate; lack of landlord investigation leaves dispute	Southern Hills: No evidence or expert showing Firestop was defective or failed	Held: Summary judgment for Defendant on Firestop theory—Plaintiff produced no affirmative evidence of defect.
Whether tenant’s alleged failure to notify landlord bars breach-of-contract claim	Samuels: lease places maintenance duties on landlord; tenant not liable for landlord’s statutory duties	Southern Hills: Plaintiff breached contractual duty to report defects, precluding recovery	Held: Court rejects defense—public policy and lease terms do not permit shifting landlord’s statutory responsibilities to tenant; summary judgment denied on contract claim except for Firestop theory.

Key Cases Cited

Jarrett v. Woodward Bros., Inc., 751 A.2d 972 (D.C. 2000) (contributory negligence cannot defeat liability for violations of statute)
Martin v. George Hyman Constr. Co., 395 A.2d 63 (D.C. 1978) (statutory mandates override common-law defenses)
Durant v. Dist. of Columbia, 875 F.3d 685 (D.C. Cir. 2017) (nonmoving party must present affirmative evidence to defeat summary judgment)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary-judgment burden and need for affirmative evidence)
Jacobsen v. Oliver, 555 F. Supp. 2d 72 (D.D.C. 2008) (public-policy defense to enforcement of contract terms)
Rong Yao Zhou v. Jennifer Mall Rest., Inc., 534 A.2d 1268 (D.C. 1987) (plaintiff must prove statutory violation was proximate cause of injuries)