District of Columbia Court of Appeals March 13, 1995, 93-CV-1092, 93-CV-1441 (Twyman v. Johnson)

FARRELL, Associate Judge:

On this appeal from a jury verdict that, among other things, awarded the plaintiff-appellant damages for retaliation under the Rental Housing Act of 1985 (the Act), the primary issues are whether the trial judge erred in directing a verdict against plaintiff on her claim for negligence and whether an independent cause of action for retaliation may be maintained under the