Closing The Gaps: Lessons From Heather Hill For Maryland Housing Policy Reform

by Molly McInnis, Associate Member, University of Cincinnati Law Review Vol. 94

I. Introduction

The recent $11.2 million Heather Hill housing settlement in Prince George’s County, Maryland offers restitution to hundreds of tenants who, for years, lived in unsanitary, unsafe, and unlicensed conditions and were forced to continue to pay rent.¹ This settlement not only exposes Heather Hill, a landlord and operator who neglected the fundamental rights of its tenants, but also the failure of Maryland’s law to prevent such violations from persisting for so long. Maryland’s legal system should pursue policy reform to ensure that the Heather Hill tenants are not only paid in damages but in the future guarantee of landlord accountability and the enforcement of tenants’ rights.

This article addresses the gaps within Maryland local and state law that failed to enforce tenants’ rights policies as well as hold accountable the landlord who disregarded such duties. Part II outlines the details of the case, reviews the current state of Maryland and Prince George’s County law, and examines other policies and regulations across the country designed to proactively enforce tenant protections. Part III identifies the gaps in current Maryland law and suggests a policy framework the state could have implemented to prevent the Heather Hill situation and to avoid similar crises in the future. Finally, Part IV offers a brief conclusion reiterating the importance of strong enforcement mechanisms aimed at protecting tenants’ rights and why Maryland should consider instituting a reformed policy framework.

II. Background

The Maryland Attorney General, Anthony Brown, recently announced an $11.2 million settlement for a landlord-tenant dispute between the Consumer Protection Division (“CPD”) and the operators of a 459-unit multi-family residential housing complex known as Heather Hill for violations of the Consumer Protection Act and the Consumer Debt Collection Act.² This settlement is the largest sum the Division has obtained in a case for tenants against a landlord.³ The order aims to provide restitution for hundreds of Maryland tenants and families who were forced to pay rent while living in unsafe conditions under a landlord who lacked proper licensing requirements.⁴ The severity of the Heather Hill situation reveals deeper flaws within Maryland tenant protection laws, where landlords can take advantage of tenants who cannot otherwise afford to break their lease or find alternative housing.

A. Heather Hill’s Violations

The problems started in April 2022 when Heather Hills Property Company purchased an apartment complex in Prince George’s County, Maryland.⁵ Heather Hill operated the complex for over two years without a required housing license.⁶ During that time, the Department of Permitting, Inspections and Enforcement (“DPIE”) issued several notices of violations to the Heather Hill operators.⁷ These violations included “reports of mold, leaks, broken heating and air conditioning, inoperable stoves and dishwashers, ‘mushrooms growing through the floors,’ and infestations of bats, insects, rodents, and roaches.”⁸ Heather Hill subsequently applied for a temporary rental housing license in May 2022, which was issued but later suspended the following August.⁹

Tyreana Brittingham, a Heather Hill tenant, reported that she was only one of three tenants in her nine-unit building due to the ongoing problems.¹⁰ Brittingham explained that she wanted to move, but could not afford it.¹¹ Despite these issues, Heather Hill “continued to charge rent [and] threatened late fees” for tenants who failed to pay.¹² In June 2024, the DPIE issued a notice of violation to Heather Hill after an inspection revealing housing and fire code violations in every residential building.¹³ These violations included broken and/or missing glass panes, discharged, missing, or expired fire extinguishers, unsanitary conditions, interior water leaks and stains, and numerous common area lighting figures that were inoperable and/or missing.¹⁴ By May 2025, over 240 failure to-pay-rent actions were filed against the tenants of Heather Hill.¹⁵

CPD filed charges against the owner of the residential complex, Heather Hill, in November 2024.¹⁶ The Maryland CPD aims to protect consumers by offering “mediation services to help resolve complaints against businesses and health insurance carriers.”¹⁷ It was only after the CPD filed its charges that Heather Hill attempt to address the issues at the complex, including taking steps to resolve code violations and obtaining a rental license in January 2025.¹⁸ The complaint alleges that Heather Hill illegally advertised, leased, and charged rent for apartments without a license and delivered units to tenants that were not properly inspected for housing and fire code violations.¹⁹ The claim asserts that consumers had come to Heather Hill “seeking legal, safe, affordable, housing for themselves and their families” due to its representation that its apartment units would not contain hazardous conditions, nor would the units be a “substantial threat to the life, health, and safety of occupant.”²⁰ Additionally, Heather Hill sought to collect debts that they knew “were not owed.”²¹ Ultimately, the complaint asserted violations of the Consumer Protection Act and the Consumer Debt Collection Act.²²

The CPD’s final order was issued on September 3, 2025, and mandated Heather Hill to pay $11.2 million in restitution to these former and current tenants.²³ In his official statement, Attorney General Brown asserted that his “office will always hold landlords accountable when they put profits over people’s safety, and [will] continue to protect Marylanders from housing providers’ irresponsible and unlawful actions that put them and their families at risk.”²⁴

B. Maryland Tenant and Consumer Protection Laws

While Maryland and Prince George’s County have strong tenant protection laws on paper, they lack the necessary enforcement mechanisms to guarantee those rights in practice. For instance, Prince George’s County Housing Code requires landlords to warrant that their rental properties are free from conditions that may “threaten the life, health, or safety of tenants.”²⁵ This Code also requires landlords to apply for and obtain a license through the DPIE to rent and lease multi-family units, ensuring compliance with all code requirements.²⁶ In addition, the Code mandates that any written lease must contain an express warranty of habitability.²⁷ The Code’s express warranty of habitability requires landlords to comply with all applicable statutes and regulations governing the maintenance, construction, use, or appearance of rental property.²⁸ These safeguards protect tenants from the moment their lease is signed and ensure landlords uphold their responsibilities throughout the lease term.

Maryland’s consumer protection laws also intend to offer tenant protection. The Consumer Debt Collection Act prohibits individuals from knowingly collecting or attempting to collect consumer debts when they are not owed, including property management companies that receive rent without a license.²⁹ The Fair Debt Collections Protections Act prohibits debt collections for using false or misleading representations in connection with the collection of debt.³⁰ The Maryland Consumer Protection Act also forbids individuals from “engaging in unfair, deceptive, or abusive trade practices in connection with […] the leasing of consumer realty and in collection of consumer debt.”³¹ These policies aim to prevent unlawful consumer practices and to help consumers obtain relief from such practices.³²

While Maryland and Prince George’s County law establish robust tenant rights, the legal system lacks effective enforcement mechanisms, which will be explored in Section III. One factor that contributes to the lack of enforcement is the complaint-based system. Additionally, the absence of proactive oversight also leaves room for landlord abuse when failing to comply with regulations.

C. Alternative State and Local Laws and Regulations

Across the country, other state and local regulations have implemented tenant protection schemes with stronger enforcement mechanisms, providing more effective safeguards for tenants. Specifically, there are alternative policies that could better address the two issues identified in Maryland’s current policy procedure: the complaint-based system and lack of proactive oversight.

Other states and local governments have implemented systems and policies aimed at mitigating limitations of complaint-based regulatory systems. One example is the New Jersey Truth in Renting Act.³³ Under this statute, every landlord must distribute a copy of the “Truth in Renting Guide” to each of their tenants prior to the lease signing.³⁴ The Truth in Renting Guide is a reference guide for tenants that provides a comprehensive overview of the state’s current landlord-tenant laws, including payment and collection of rent, habitability, evictions, filing complaints, and consumer fraud protection.³⁵ Landlords are also required to redistribute a copy of the guide to each of their tenants within thirty days after being updated and made available by the Department of Community Affairs (“DCA”).³⁶ This policy helps tenants understand their rights and responsibilities “at the time when [they] need reliable information.”³⁷

Another policy that seeks to inform tenants of their rights is the Washington District of Columbia (“DC”) business licensing system.³⁸ Under this policy, any business operating as a corporate entity (such as a limited licensing company) must obtain a Basic Business License (“BBL”).³⁹ Landlords in DC are required to obtain BBLs to operate legally, ensuring that they comply with legal laws and properly maintain rental units.⁴⁰ The BBL system not only administers, stores, and renews these licenses, but it also houses a public license information service.⁴¹ Any member of the public, upon request, may access all required information, documents, and approvals for each BBL previously issued by the DC government.⁴²

Other states and local governments have developed approaches to the second issue highlighted by the Heather Hill situation–the lack of proactive oversight. One example is the City of Boston Housing Code’s rental inspection service.⁴³ This policy requires the city to randomly inspect every rental property at least once every five years.⁴⁴ Under this program, all owners of rental units (with few exemptions) must register with the Inspection Services Department (“ISD”).⁴⁵ Failure to register results in fines and several other enforcement actions.⁴⁶ The registered units are inspected at least once every five years by the ISD or an ISD approved and state-certified inspector.⁴⁷ The program designates “problem properties” as units that, within a twelve-month period, meet the following criteria: (i) police have been called four or more times for any arrestable offense; (ii) at least four noise complaints have been filed; or (iii) at least four complaints have been submitted to the ISD regarding unsanitary, unhealthy, or noxious conditions.⁴⁸ These problem properties undergo annual inspections.⁴⁹ Any “chronic offenders” of the housing code are classified by their repeated noncompliance, such as failure to register, repeated violations, and failure to correct violations.⁵⁰ These properties also undergo more frequent ISD inspections.⁵¹ If landlords fail to comply with the program, they may face fines, court injunctions, or criminal prosecution.⁵² This program seeks to “maximize the effectiveness of city resources in rental property code enforcement” while protecting the interests of public health and safety.⁵³

III. Discussion

The operators of Heather Hill not only violated basic tenant and consumer rights, but continued to operate, collect rent, and file evictions despite blatantly disregarding its legal obligations. As discussed, Maryland and Prince George’s County have codified strong tenant protections. However, they lack the effective enforcement mechanisms to uphold these standards. Two major shortcomings of this policy framework include the complaint-based system and absence of proactive oversight. By addressing such gaps in the law, Maryland could have prevented the harm caused by Heather Hill. With the settlement now finalized, Maryland and Prince George’s County should prioritize correcting these shortfalls to prevent similar crises from occurring in the future. Ultimately, Maryland should pursue policy reform that addresses the limitations of purely complaint-based systems and limited proactive regulation.

A. The Gaps in Maryland Law

While Maryland and Prince George’s County have robust tenant and consumer protection laws on paper, these statutes lack effective enforcement mechanisms to guarantee that tenants can exercise these rights. There are two large issues that could have contributed to the Heather Hill situation. The first issue lies in the complaint-based structure of these policies.⁵⁴ To hold landlords accountable for code or statutory violations, the law relies on tenants to initiate a complaint.⁵⁵ This approach assumes that tenants are both willing to file a complaint and are aware of their rights and the proper procedures to do so. This assumption is not always correct. A problem of this nature may prevent tenants from filing complaints for breach of warranty of habitability or inadequate licensing, as illustrated by the Heather Hill case.

A second factor that may have exacerbated the Heather Hill situation was the absence of proactive legal enforcement. Despite tenants filing maintenance requests, complaints, and a lack of proper licensing, Heather Hill collected rent and threatened evictions for tenants who did not pay their rent for years.⁵⁶ Had local and state agencies maintained closer oversight of the property, the operators of Heather Hill may have been prevented from engaging in such conduct. However, despite Heather Hill’s repeated violations, no measures effectively stopped them from operating in this manner for years.

B. Overcoming the Limitations of the Maryland Complaint-Based System

To protect tenants in situations such as Heather Hill, Maryland should consider implementing a policy like the New Jersey Truth in Renting Act. As discussed, this statute requires landlords to provide a “Truth in Renting Guide” to each tenant before their lease is signed.⁵⁷ This guide provides a comprehensive overview of each tenant’s rights and obligations.⁵⁸ By requiring landlords to provide tenants with a clear and navigable guide to their legal protections, tenants are given the best opportunity to understand their rights. This approach helps tenants identify when a landlord has breached their legal duties, what remedies are available to them, and what course of action to take. This policy addresses limitations of the complaint-based system by actively providing tenants with the necessary information they need to protect themselves. Had the Heather Hill tenants had access to such a resource, many tenants would have been able to identify the warranty breaches within their homes, and more effectively alert the housing authorities of the issue. Maryland should consider implementing a similar statute to strengthen tenant protections within a complaint-based framework.

Another approach Maryland should consider is a business licensing system. Like the BBL program in DC, Maryland could implement a program where landlords are routinely licensed based on standardized criteria, and those licenses are made accessible through a public database. The fact that Heather Hill, housing hundreds of tenants, was able to operate unlicensed for years highlights a gap within the current licensing procedures. Implementing a public licensing database would have enabled tenants and other enforcement institutions to more readily discover that Heather Hill was operating and collecting rent without a proper license. By implementing this resource alongside a “Truth in Renting Guide,” tenants could be informed on the importance of the landlords holding a valid license and how to verify whether a license has been obtained. This policy would help overcome the limitations of the complaint-based system by not only educating tenants but giving them tools to hold landlords accountable.

C. Implementing Proactive Oversight in Maryland

Another factor that contributed to the gap in Maryland law was the lack of proactive oversight. Despite complaints that had been filed by tenants, Heather Hill continued to operate for years despite flagrant housing violations. This issue illustrates the weakness in Maryland’s enforcement regime. Maryland should consider a reoccurring inspection program to address this problem. As mentioned, the ISD run program in Boston randomly inspects every rental unit in the city at least once every five years.⁵⁹ The program targets offenders of the housing code by initiating more frequent inspections by classifying “problem properties” and “chronic offenders.”⁶⁰ Failure to comply with such policies may result in fines, court injunctions, or criminal prosecution.⁶¹ This policy adopts a proactive strategy that promotes compliance with tenant protection laws while providing remedial measures in the event that violations occur.

The tenants of Heather Hill would have benefited from such a program. Not only would Heather Hill have been subject to the standard five-year random inspection cycle, but it could have also faced more frequent inspections and fines if designated as a “problem property.” Under the Boston policy, if the ISD or the Public Health Commission receives at least four complaints within a twelve-month period regarding noxious or unsanitary conditions in a unit, the property is designated a “problem property.”⁶² Considering the reported condition of the Heather Hill units and the hundreds of maintenance requests and complaints that had been filed, it is likely Heather Hill would have been classified as a “problem property.” As a result, Heather Hill would have been subject to annual inspection and required to provide a remediation plan to the city.⁶³ Failure to comply with such requirements would have resulted in punitive measures. Had Maryland or Prince George’s County utilized such a system, it is probable that Heather Hill’s violations would have been more readily identified by the housing authorities, placed under review and oversight for remediation, or punished for a continuation of violations. By implementing such a program, Maryland could more effectively identify similar issues and address them before escalating to the severity experienced at Heather Hill.

IV. Conclusion

The Heather Hill settlement is not just a story of a landlord disregarding their legal obligations to their tenants, but a window into the deeper failings of the Maryland tenant protection laws. While Maryland has implemented strong guarantees on paper, it lacks practical enforcement. The Heather Hill case illustrates the shortfalls of the complaint-based system and a lack of proactive oversight. By enacting policy reform, Maryland and Prince George’s County can provide justice to the Heather Hill tenants not only through restitution, but also through the legal assurance that such flagrant violations will never happen again.

Cover Photo by Erik Mclean on Unsplash

Molly McInnis

References

1
Attorney General Brown Announces Multi-Million Dollar Settlement with Property Owner and Operator of Heather Hill Apartments, a Prince George’s County Multi-Family Rental Housing Community, Att’y Gen. of MD. (Sep. 11, 2025), https://oag.maryland.gov/News/Pages/Attorney-General-Brown-Announces-Multi-Million-Dollar-Settlement-with-Property-Owner-and-Property-Operator-of-Heather-Hill-.aspx [https://perma.cc/SDT3-HPSB] [hereinafter Multi-Million Dollar Settlement].
2
Id.
3
Id.
4
Id.
5
Jenny Gable, Maryland Attorney General Announced Charges Against Temple Hills Apartment Complex, D.C. News Now (Nov. 13, 2024), https://www.dcnewsnow.com/news/local-news/maryland/prince-georges-county/maryland-attorney-general-announces-charges-against-temple-hills-apartment-complex/ [https://perma.cc/5W5R-N2ZM].
6
Multi-Million Dollar Settlement, supra note 1.
7
Gable, supra note 5.
8
Id.
9
Id.
10
Haley Parsley, State Orders Apartment Manager to Pay $11.2M to Prince George’s Tenants in Landmark Case, Cap. News Serv., https://cnsmaryland.org/2025/09/17/state-settles-landmark-case-for-prince-georges-tenants/ (last visited Oct. 20, 2025) [https://perma.cc/Z8MJ-ULWW].
11
Id.
12
Id.
13
Complaint at 16, Consumer Prot. Div., Office of the Att’y Gen. v. Heather Hill, No. 24-021-373461 (2024), https://650b652c-9317-436f-9be1-1ee0e34e386f.usrfiles.com/ugd/650b65_fdb403cb72eb4fcf8a5745a76b3ee643.pdf [https://perma.cc/9BPY-MWC5].
14
Id.
15
Multi-Million Dollar Settlement, supra note 1.
16
Parsley, supra note 10.
17
Multi-Million Dollar Settlement, supra note 1.
18
Id.
19
Complaint, supra, note 13, at 2.
20
Id.
21
Id.
22
Id.
23
Multi-Million Dollar Settlement, supra note 1.
24
Id.
25
Complaint, supra, note 13, at 6-7.
26
Id. at 8.
27
Id.
28
Prince Geo. Cnty., MD. Code of Ordinances § 13-162 (2025).
29
Complaint, supra note 13.
30
Id.
31
Id.
32
Id.
33
Truth In Renting: A guide to the rights and responsibilities of residential tenants and landlords in New Jersey, Dept. of Community Affairs, https://www.nj.gov/dca/codes/publications/pdf_lti/t_i_r.pdf (last visited Oct. 23, 2025) [https://perma.cc/NKD3-RDZ7].
34
Id.
35
Id.; August 20, 2020 – DCA Announces that New Edition of Truth in Renting Guide Is Now Available, N.J. Dept. of Cmty. Affs. (2020), https://www.nj.gov/dca/news/news/2020/20200820.html[https://perma.cc/T8XB-GMEE]
36
Id.
37
Id.
38
Steps to Obtaining a Basic Business License, D.C. Dept. of Licensing and Consumer Prot., https://dlcp.dc.gov/node/1618236 (last visited Oct. 20, 2025) [https://perma.cc/C7RB-Z2ZZ]; D.C. Code § 47-2851 (2025).
39
Steps to Obtaining a Basic Business License, supra note 38.
40
The Essential Guide to Obtaining a Basic Business License as DC Landlord, D.C. Landlord Assoc., https://www.dclandlord.org/blog/basic-business-license (last visited Oct. 20, 2025) [https://perma.cc/QA96-AKVT].
41
D.C. Code, supra note 39.
42
Id.
43
When You Need a Rental Inspection, City of Bos., (2025), https://www.boston.gov/departments/inspectional-services/when-you-need-rental-inspection [https://perma.cc/8MUE-79PV]; City of Bos., Code of Ordinances § 9-1.3 (2024).
44
City of Bos., supra note 43.
45
Id.
46
Id.
47
Id.
48
Id.
49
Id.
50
Id.
51
Id.
52
Id.
53
Id.
54
Landlord/Tenant Disputes, Att’y Gen. of MD., https://oag.maryland.gov/i-need-to/Pages/landlord-tenant-disputes.aspx (last visited Oct. 20, 2025) [https://perma.cc/6DTG-DL4F]; Permitting, Inspections and Enforcement: Rental Housing License, Prince Geo. Cnty. MD., https://www.princegeorgescountymd.gov/departments-offices/permitting-inspections-and-enforcement/licensing/rental-housing-licenses (last visited Oct. 20, 2025) [https://perma.cc/QU4L-H3ZA].
55
Att’y Gen. of MD., supra note 54; Prince Geo. Cnty. MD., supra note 54.
56
Multi-Million Dollar Settlement, supra note 1.
57
N.J. Dept. of Community Affairs, supra note 35.
58
Id.
59
When You Need a Rental Inspection, supra note 43.
60
Id.
61
Id.
62
Id.
63
Id.