An estate, attempted to be created for a greater term than one year in real estate, other than by deed, is an estate by sufferance.
D.C. Code § 28-3501
Estate created otherwise than by deed
Aug. 30, 1964, 78 Stat. 676, Pub
Official source: D.C. Law Library (Council of the District of Columbia). Reproduced from public-domain District of Columbia statutes; confirm against the official source for the current text. Not legal advice.