Is it necessary to use a primer to before covering a semi-gloss latex paint with a flat latex paint?

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I recently moved out of my apartment. I had painted the bedroom a light shade of green that could easily be covered with 1 layer of paint by the apartments after I moved out. They are charging me the cost of repainting because they said they had to use a primer since I had used a semi-gloss paint and they use flat. Is this true?

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  1. If the painter who paints the wall knows what he's doing, a primer is really not required… but careful rolling is required and to be sure a "wash coat" using the finish coat paint, could be applied first, which would act as a primer… then when dry (1hr) a finish coat carefully rolled will do the trick… all of this assumes that a High Quality Paint is being used (often not the case with apt repainting)…

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