D.C. Court of Appeals holds that under pre-2017 law, a condominium association could not foreclose its lien subject to a first-position deed of trust, where part of the lien enjoyed super-priority, and the remainder being inferior to the deed of trust. 

D.C. Court of Appeals affirmed the trial court’s dismissal of negligence and conversion claims by litigation financier’s against attorneys who released the settlement proceeds directly to the client, refusing a demand to honor client’s separate assignment of such proceeds.