SJ Enterprises, LLC v. Dianne Quander

Summary

The District of Columbia Court of Appeals held that a landlord waived the contractual deadline for a tenant to exercise a lease renewal option through the landlord’s email communications and conduct. The tenant reasonably relied on the email exchange and exercised the renewal option for an additional five-year term. The court vacated the trial court’s judgment and remanded for entry of judgment in favor of the tenant.

Holdings

1. A landlord may waive a contractual deadline for timely notice of a lease-renewal option through words or conduct inconsistent with an intent to enforce that deadline. Quander's email and related conduct clearly and unequivocally waived the deadline, allowing SJ Enterprises to exercise the renewal option for a second five-year term.
2. The parties' email exchange did not create a new lease; the trial court erred as a matter of law in treating it as a new contract.

Questions Presented

1. Whether Quander's conduct and communications after expiration of the lease-renewal deadline waived her right to insist on timely notice of the renewal option.
2. Whether the parties' email exchange created a new lease agreement.
3. Whether the statute of frauds limited the enforceability of the parties' arrangement to one year.

Disposition

reversed_and_remanded