United States District Court, District of Columbia
May 19, 2014
CHAITRI HAPUGALLE, Plaintiff,
THE CHASTLETON COOPERATIVE ASSOCIATION, et al., Defendants.
BERYL A. HOWELL, District Judge.
This matter is before the Court on the plaintiff's application to proceed in forma pauperis and her pro se complaint.
Plaintiff acquired "multiple shares equivalent to two units (Apartments 611 and 409) in the Chastleton Cooperative Association, Inc." Am. Compl. at 9 (page numbers designated by plaintiff). In Apartment 409, plaintiff "mostly [conducted] a bona fide consulting job." Id. She leased Apartment 611 to two tenants, collected $3, 000 per month, id. at 9-10, 12, and used that income "to maintain [Apartment] 611 and also subsidize[d] some part of the expenses for [Apartment] 409, " id. at 12. A dispute arose between plaintiff, the cooperative association, and its property manager, see generally id. at 10-12, resulting in, among other things, the denial of plaintiff's request to lease her second unit, see id. at 13-14. This loss of rental income, coupled with plaintiff's medical condition and related expenses, see id. at 16, apparently caused plaintiff to fall behind on co-op fees and other assessments, see id. at 18.
Based on the Court's review of plaintiff's submissions and exhibits, it appears that plaintiff brought a discrimination claim against the defendants before the District of Columbia Office of Human Rights. See id. at 19. It further appears that proceedings against plaintiff in the Landlord and Tenant Branch of the Superior Court of the District of Columbia have resulted in "a non-redeemable judgment for [Apartment] 611..., " as well as a judgment in defendants' favor with respect to Apartment 409. Id. at 21.
Under the doctrine of res judicata, a prior judgment on the merits of a claim bars a plaintiff from relitigating the same claim. See I.A.M. Nat'l Pension Fund v. Indus. Gear Mfg. Co., 723 F.2d 944, 949 (D.C. Cir. 1983) (noting that res judicata "forecloses all that which might have been litigated previously"). "[W]here res judicata applies, it bars relitigation not only as to all matters which were determined in the previous litigation, but also as to all matters that might have been determined." Natural Res. Def. Council, Inc. v. Thomas, 838 F.2d 1224, 1252 (D.C. Cir. 1988) (citation omitted); see Allen v. McCurry, 449 U.S. 90, 94 (1980). In evaluating a cause of action for res judicata purposes, it is the factual nucleus that gives rise to a plaintiff's claim, not the legal theory on which the claim rests, that determines whether the claim may proceed. Page v. United States, 729 F.2d 818, 820 (D.C. Cir. 1984).
Plaintiff purports to bring this action under the Fair Debt Collection Practices Act, see id. at 1, 20, and she also alleges "[o]ther related violations [including] tortious interference of contract, extortion, fraud, harassment, defamation and retaliation, " id. at 1. These alleged harms necessarily would have occurred in the course of events leading to and during litigation in the Superior Court. Plaintiff cannot now bring a claim that she already has brought or that she could have brought against these defendants in the Superior Court. Nor can she demand review of any decision rendered by the Superior Court because a federal district court "lack[s] jurisdiction to review judicial decisions by state and District of Columbia courts." Richardson v. District of Columbia Court of Appeals, 83 F.3d 1513, 1514 (D.C. Cir. 1996) (citing District of Columbia v. Feldman, 460 U.S. 462, 476 (1983) and Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923)).
The Court concludes that the complaint, as amended, fails to state a claim upon which relief can be granted. Accordingly, the complaint will be dismissed. An Order accompanies this Memorandum Opinion.