Steven Ray Collins and Sharon Lavette Collins, proceeding pro se, appealed a district court judgment that dismissed their lawsuit alleging violations of the Fair Housing Act against Wells Fargo & Company and Wells Fargo Bank, N.A. The underlying dispute arose after the district court granted a motion to dismiss the case based on the doctrine of res judicata. The Collinses argued that the dismissal was improper, but the district court determined that their claims were barred because they had previously litigated the same matter in state court, which resulted in a final judgment on the merits. The Collinses contend that the district court erred by considering matters beyond the pleadings and by denying them an oral hearing.
The Ninth Circuit reviewed the dismissal de novo, applying California state law to determine the preclusive effect of the prior state court judgment. The court explained that under California law, res judicata bars a subsequent action if it involves the same cause of action between the same parties following a final judgment on the merits in the first suit. The court emphasized the rule that conduct violating a single primary right gives rise to only one cause of action, meaning the Collinses could not relitigate the same legal theory in a new suit. Regarding the procedural complaint, the court noted that Federal Rule of Civil Procedure 78(b) allows courts to decide motions on briefs without oral hearings. Citing Ninth Circuit precedent, the court found that the district court did not violate the Collinses' procedural due process rights because they had a full opportunity to present their arguments in writing. Finally, the court rejected the argument that the district court improperly considered matters beyond the pleadings, stating that courts may take judicial notice of matters of public record without converting a motion to dismiss into a motion for summary judgment.
The Collinses' Fair Housing Act claims are permanently barred, and the judgment against them stands. This decision reinforces the strict application of res judicata in the Ninth Circuit, particularly when California law governs, preventing litigants from splitting a single primary right into multiple lawsuits. The ruling also clarifies that district courts have broad discretion to decide motions to dismiss without oral hearings, provided the parties have had a chance to submit written arguments. No further action is available to the Collinses on these specific claims unless they can identify a distinct primary right or a new cause of action not previously adjudicated.
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