| Court: | DC Court of Appeals |
| Facts: | Tenants had 1,500 code violations, and began witholding rent. |
| Posture: | At trial, the court ruled that evidence of code violations was inadmissile when proffered as a defense to eviction. The court of appeals upheld this ruling. Appeal. |
| Issue: | Do housing code violations arising during the term of a lease affect a tenant's obligation to pay rent? |
| Holding: | Yes. |
| Rule: | Breach of the warranty gives rise to the usual contract remedies. |
| Reasoning: | Used to be that a lease was an interest in land. Nowadays, it's generally shelter, which implies a combination of goods and services. Implied warranties are a part of modern commerce: reliance on expert vendors. Tenants aren't able to make all repairs, they have very little leverage to make their demands heard, bad housing is detrimental to the whole society. |
| Dicta: | |