The public interest may extend to the use of land. What in its immediate aspect may be only a private transaction may be raised by its class or character to a public affair.
The landlord asserted that the District of Columbia Rents statute was unconstitutional because it authorized the taking of private property without due process of law. The statute permitted tenants to remain in their rental property beyond the expiration of the term of their lease so long as rent payments were continued. The lower court found in favor of the landlord. The tenant challenged the judgment, contending that the statute was not void because it was justified by public exigency.
Was the statute that authorized the tenants to remain in their rental property beyond the expiration date if they continued to pay rent unconstitutional?
The court reversed the decision of the lower court that found in favor of the landlord. The court held that the statute was not unconstitutional because its provisions were necessary to address housing issues resulting from a public emergency. The court agreed with the tenant's contention, finding that the statute was not unconstitutional because the statute's requirements had a reasonable relation to the relief sought. The court held that the legislature enacted the statute in part because of public health concerns resulting from severe housing limitations due to increased residency in the District of Columbia related to the war. The court noted that the statute was proper because it was limited in time and provided for the landlord to receive reasonable rent during the extended tenancy period.