2348 Ainger Place Tenants Association, Inc. v. District of Columbia

Summary

The District of Columbia Court of Appeals held that the Superior Court lacked jurisdiction to review a challenge to the Mayor's decision regarding registration of a tenant organization under the Rental Housing Conversion and Sale Act. Such challenges were required to be brought by petition for review in the Court of Appeals under the Act and the District of Columbia Administrative Procedure Act. The court affirmed dismissal of the action, although on jurisdictional grounds rather than the trial court's stated standing and exhaustion grounds.

Holdings

1. The Superior Court lacked jurisdiction to review the CCCSB's decision concerning registration of a tenant organization because the Rental Housing Conversion and Sale Act assigns exclusive judicial-review jurisdiction over final Mayoral and agency actions to the District of Columbia Court of Appeals.
2. An agency's inaccurate statement that Ainger Place could file suit in the Superior Court could not confer jurisdiction that the Superior Court otherwise lacked.
3. The denial of a trial-type hearing by the CCCSB did not authorize Ainger Place to file an original action in the Superior Court; any hearing entitlement or related error could be addressed through appellate review in the Court of Appeals.

Questions Presented

1. Whether the Superior Court had jurisdiction over Ainger Place's challenge to the CCCSB's decision rejecting its registration application and registering April House.
2. Whether Ainger Place could bring an original civil action in the Superior Court under D.C. Code § 42-3405.03 rather than petitioning the District of Columbia Court of Appeals for review under § 42-3405.09.
3. Whether the CCCSB's failure to provide the administrative hearing sought by Ainger Place authorized Ainger Place to seek that hearing through an original action in the Superior Court.

Disposition

affirmed