NELBACH v. NELBACH

No. 22-CV-0200.

291 A.3d 1129 (2023)

Theodore Albert NELBACH, Appellant, v. Willow NELBACH, Appellee.

District of Columbia Court of Appeals.

Decided April 6, 2023.


Attorney(s) appearing for the Case

Anna L. Nathanson for appellant.

David E. Bateman , with whom Daniel M. Rathbun , Fairfax, VA, was on the brief, for appellee.

Before Beckwith, Easterly, and McLeese, Associate Judges.


The concept of "waste" with respect to real property in American law is many centuries old and traces back to statutes enacted in the 13th century by the nascent English Parliament. Our focus in this case is on one of these statutes, the Statute of Gloucester. As translated in the mid-1700s from its original Norman French...

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