The D.C. Court of Appeals upheld the trial court's finding that the transfer of the apartment building from the sole owner to a limited-liability company controlled by the same owner is not a "sale" that would implicate the tenants' statutory right of first refusal. The absence of an arm's-length relationship and the transfer to the grantor's effectively wholly owned company indicate that the transaction was a restructuring, not a sale.
Wallasey Tenants Association, Inc. v. Varner
D.C. Ct. App.
February 16, 2006