Edwards v. Habib, 397 F.2d 687 (D.C. Cir. 1968)

Holding:
D.C. Circuit (J. Skelly Wright) — the foundational U.S. retaliation case. Held that a landlord may not evict a tenant in retaliation for the tenant's good-faith report of housing-code violations to public authorities. The court reasoned that to permit retaliatory eviction would render housing-code enforcement nugatory and frustrate the legislative intent behind code regulation. Cited nationwide and incorporated by reference into virtually every modern state retaliation statute (Mass. ch. 186 § 18; Conn. § 47a-20; Me. § 6001; Vt. § 4465; Mont. § 70-24-431; Ky. § 383.705 (URLTRA)). Federal anti-interference now also expressed at 42 U.S.C. § 3617 (FHA) for protected-class retaliation.