District of Columbia Court of Appeals

Admadu v. Bockai, Sr.

September 3, 2026

Summary

The D.C. Court of Appeals reversed the trial court’s finding that Bockai acquired the Anacostia property by adverse possession, vacated the gift analysis and attorney‑fees award, and remanded for further proceedings. The court held that Bockai’s possession was not hostile because Ahmadu, the legal titleholder, had granted him a power of attorney, and that a person cannot give what he does not own.

Holding

  • Whether Bockai established the requisite elements of adverse possession of the property.. The trial court’s adverse‑possession ruling is reversed; Bockai did not establish adverse possession because his possession was permissive, not hostile, under Ahmadu’s power of attorney.
  • Whether the trial court erred in concluding that Bockai did not gift the property to Ahmadu.. The trial court’s gift analysis is vacated and remanded for further determination.
  • Whether the trial court properly awarded attorney’s fees and costs to Bockai.. The award of attorney’s fees and costs to Bockai is vacated.
  • Whether the trial court’s adjudication of Bockai’s unjust‑enrichment claim should be vacated.. The unjust‑enrichment portion of the trial court’s order is vacated and the claim is remanded for further proceedings.

Docket 24-CV-1150

Cited authorities

  • D.C. Code § 12-301
  • D.C. Code § 17-305
  • D.C. Code § 17-305