Rock Creek Gardens Tenants Ass'n v. Ferguson

Appellant, a voluntary unincorporated association of tenants, seeks reversal of the trial court’s dismissal of its complaint. The question presented to us on appeal is one of first impression in this court. The issue is whether a voluntary unincorporated association has the legal capacity to hold title to real estate within the meaning of § 602(b) of the Rental Housing Act of 1977. 1 Finding that appellant does not have such legal capacity, we affirm.

Rock Creek Gardens, an apartment complex at 2511 Q Street, N.W., Washington, D. C., was owned, at the relevant time of this suit, by A. M. and…