Koehne v. Harvey

I cannot agree that Harvey was landlord of Koehne and therefore cannot agree that Harvey was entitled to maintain the action. Koehne’s tenancy commenced under his lease from Fisher and Company. When the property was conveyed to the new owners they became Koehne’s landlords with the same rights as the former landlord. Code 1940, § 45 — 932; Bailey v. Allan E. Walker & Co., Inc., 53 App. D.C. 307, 290 F. 282; Selden v. Lee, 55 App.D.C. 164, 3 F.2d 335. No attornment by Koehne to the new owners was necessary. Code 1940, § 45—933. Thus, the relationship of landlord and tenant was created between…