Legal Question in Civil Litigation in California
In the final appelate and/or supreme court ruling, did res judicata apply in Vella v. Hodgins?
1 Answer from Attorneys
Do you mean Vella v. Hudgins (1977) 20 Cal.3d 251?
The key holding in that case is that a judgment in an unlawful detainer proceeding has a very limited res judicata effect and will not prevent one who is dispossessed from real property from bringing a subsequent action to resolve questions of title. The issue in that case was whether Nancy Vella had her "day in court" in the unlawful detainer action as to issues of fraud. The California Supreme Court ruled that the record failed to show that she had a fair hearing on the fraud issues, and the municipal court (now unlimited jurisdiction of Superior Court) did not have jurisdiction to hear and adjudicaqte title to property worth more than $5,000.