Mazza v. HOUSECRAFT LLC
2011 D.C. App. LEXIS 215
| D.C. | 2011Background
- 2004 home improvement contract: Housecraft agreed to renovate Mazza's property.
- Housecraft filed a mechanic's lien and a suit for balance; Mazza disputed the amount and counterclaimed.
- 2008 trial court judgment favored Housecraft for $21,757.76 plus pre-judgment interest at 1.5%, with some meritoriousness to Mazza's counterclaim.
- Writ of fieri facias was issued to enforce the lien after Mazza failed to satisfy the judgment.
- Mazza filed a 2009 challenge to the writ, triggering a Rule 12(b)(6) dismissal on res judicata grounds.
- Mazza moved for leave to amend or appeal the prior judgment; trial court denied these requests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does res judicata bar Mazza's current complaint? | Mazza argues new latent defects and post-judgment events defeat res judicata. | Housecraft contends the prior judgment and factual nucleus foreclose new claims. | Yes; res judicata bars the complaint. |
| Did the trial court abuse its discretion denying leave to amend or appeal the prior judgment? | Mazza contends newly discovered defects and fraud entitle amendment or appeal. | Housecraft argues no meritorious amendment and timely appeal were possible; Rule 60(b) not satisfied. | No abuse of discretion; denial affirmed. |
| Was Mazza's appeal of the prior judgment properly handled as void or timely? | Mazza claims void/voidable judgment due to vagueness and lack of notice to challenge interest date. | Housecraft asserts February 4, 2008 judgment was final and timely appeal time lapsed; statute of repose inapplicable. | Yes, time-barred; no voiding relief; appeal denied. |
Key Cases Cited
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (U.S. 2009) (pleading must include plausible factual allegations)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading requires more than an unadorned accusation)
- Solers, Inc. v. Doe, 977 A.2d 941 (D.C.2009) (identifies pleading standards under local rules)
- Stutsman v. Kaiser Found. Health Plan of the Mid-Atlantic States, Inc., 546 A.2d 367 (D.C.1988) (final judgment on the merits forecloses relitigation)
- Shin v. Portals Confederation Corp., 728 A.2d 615 (D.C.1999) (res judicata bars new defenses raised in later actions)
- Tutt v. Doby, 265 A.2d 304 (D.C.1970) (defenses to lease disputes barred by prior litigation)
- Olivarius v. Stanley J. Sarnoff Endowment for Cardiovascular Sci., Inc., 858 A.2d 457 (D.C.2004) (Rule 60(b) relief as last resort for grave miscarriages)
- P'ship Placements, Inc. v. Landmark Ins. Co., 722 A.2d 837 (D.C.1998) (fraud on the court generally not grounds for Rule 60(b) relief)
- Allen v. Yates, 870 A.2d 39 (D.C.2005) (pre-judgment interest is proper where debt is liquidated and contract permits)
- House of Wines, Inc. v. Sumter, 510 A.2d 492 (D.C.1986) (clarifies discretion in awarding pre-judgment interest)