What Happened: A D.C. Housing Authority (DCHA) resident pled guilty to criminal gun charges—possession of an unregistered firearm—after police officers carrying out a search warrant seized loaded handguns from his apartment. A few days later, the DCHA sent him an eviction notice for allegedly engaging in criminal activity that threatened the health, safety, or right to peaceful enjoyment of other residents. While acknowledging that it had never had any negative interactions with or reports about the tenant, the DCHA argued that being convicted of possessing an unregistered firearm was enough to prove that he was a threat justifying eviction without notice or the opportunity to cure under the “one-strike” clause of his lease. The lower court agreed and granted the eviction order. 

Ruling: The D.C. Appeals Court held that the lower court was wrong and reversed the ruling.

Reasoning: The criminal offense in this case wasn’t having guns in the apartment but failing to register them. While gun registration “is a useful method to curb illegal gun activity,” the court reasoned that mere lack of registration wasn’t per se proof that the tenant endangered other residents’ health, safety, or quiet enjoyment. It’s “not difficult to conjure situations in which the registration status of a gun would” have no impact on the danger it poses to public safety, the court reasoned. To justify a one-strike eviction, the DHCA also had to “make an individualized assessment” showing that the tenant’s possession of an unregistered firearm was an actual violation of the endangerment clause. Since the DCHA didn’t do that, it had no cause to evict. 

• Hattix v. D.C. Hous. Auth., 334 A.3d 607, 2025 D.C. App. LEXIS 97, 2025 LX 83275