Cooley v. Suitland Parkway Overlook Tenants' Ass'n

TERRY, Associate Judge:

In this case we must decide whether a landlord who seeks to evict a tenant for violation of an obligation under the tenancy must give the tenant a notice to quit under D.C.Code § 45-1406 (1981), in addition to a notice to cure or vacate under D.C.Code § 45 — 1561(b) (1981). We hold that in light of a recent change in the law embodied in section 45-1561(b), no additional notice to quit under section 45-1406 is required.

On October 30, 1981, appellant was personally served with a “Notice to Correct Violations of Obligations of Tenancy or Vacate.” The notice declared that…