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Cormier v. McRae, 609 A.2d 676 (1992)

Citation
Cormier v. McRae, 609 A.2d 676 (1992)
Parent Document
Cormier v. McRae, 609 A.2d 676 (1992)
Jurisdiction
DC (municipal)
Effective Date
1992-05-12

Full Text

1,014 chars
This reasoning in Jones could be read to justify appellee's argument that the § 45-1402 timing provision should be held to supplement the 30-day notice requirement under § 45-2551(b) because they can "be read harmoniously" together. Id. Two years after Jones, however, we decided Cooley v. Suitland Pkwy.Overlook Tenants' Ass'n, 460 A.2d 574 (D.C. 1983), a suit for possession based on alleged violation of a lease obligation limiting residency in the apartment to family members and others named in the rental application. We noted in Cooley that the law since Jones had changed — i.e., that the 1980 Rental Housing Act, in supplanting the 1977 Act, had made "it explicitly clear that a notice to cure or vacate is all that a landlord is required to give to a tenant before filing suit for possession based on a tenant's failure to correct a violation of the tenancy." Id. at 575-76. Thus, a separate "notice to quit" was no longer required; the 1980 Act "merg[ed] both notice requirements into one." Id. at 576.6