Brown v. Southall Realty Co.

Southall Realty (plaintiff) knowingly rented an apartment with unrepaired housing code violations — including an obstructed toilet, a broken railing, and insufficient basement ceiling height — to Mrs. Brown (defendant), even though D.C. housing regulations barred renting the unit until those violations were fixed. When Brown fell behind on rent, Southall sued to collect; Brown admitted the arrears but argued the lease itself was illegal and unenforceable given the known code violations. The trial court ruled for Southall, and Brown appealed.