955 F. Supp. 2d 1
D.D.C.2013Background
- Plaintiff Lidia Emelinda Perez Crabbe rented a storage unit from National Self Service Storage and disputed rent/timeliness, late fees, and denial of access to her property.
- Crabbe filed a Superior Court D.C. action (No. 2011 CA 004741 B) alleging improper late fees, refusal to accept rent, denial of access, and threats to dispose of property; she attached a written statement to that complaint.
- After a bench trial in Superior Court, judgment entered for the defendant on November 5, 2012, and the court awarded defendant $2,415 on its counterclaim for unpaid rent and fees.
- Crabbe subsequently filed a virtually identical complaint in federal court (this action), seeking $100,000 for alleged losses and alleging breach of contract and fraudulent charges.
- Defendant moved to dismiss under Rule 12(b)(6)/12(c) arguing the federal suit is barred by res judicata because it involves the same parties, facts, and causes of action already finally decided in Superior Court.
- The District Court found all elements of res judicata satisfied and granted defendant’s motion, dismissing the federal complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Crabbe’s federal suit is barred by res judicata | Challenges aspects of prior proceedings (e.g., Superior Court denial of injunctive relief) but does not rebut claim preclusion; contends rights remain | Prior Superior Court judgment on the merits involving same parties and same nucleus of facts precludes relitigation | Court held res judicata bars the federal suit and dismissed the complaint |
| Whether dismissal on res judicata may be raised by motion before answer (Rule 12) | Implied opposition pointing to prior court rulings but did not directly contest procedural posture | Raised res judicata in a pre-answer motion under Rule 12(b)(6)/12(c) | Court allowed res judicata as a basis for dismissal under Rule 12 standards and treated Rule 12(c)/12(b)(6) standard as applicable |
Key Cases Cited
- Baldwin v. Iowa State Traveling Men’s Ass’n, 283 U.S. 522 (1931) (public policy supports finality of litigation)
- Parklane Hosiery Co. v. Shore, 439 U.S. 322 (1979) (res judicata bars second suit based on same cause of action)
- Migra v. Warren City Sch. Dist. Bd. of Educ., 465 U.S. 75 (1984) (federal courts must give state-court judgments the same preclusive effect they would have under state law)
- Cromwell v. County of Sac, 94 U.S. 351 (1876) (final judgment on the merits bars claims that could have been raised)
- Apotex, Inc. v. Food & Drug Admin., 393 F.3d 210 (D.C. Cir. 2004) (res judicata elements defined)
- Drake v. Fed. Aviation Admin., 291 F.3d 59 (D.C. Cir. 2002) (same-cause-of-action inquiry focuses on shared nucleus of facts)
- Page v. United States, 729 F.2d 818 (D.C. Cir. 1984) (cause of action defined by facts surrounding the transaction)