In Vella v. Hudgins (1977) 20 Cal.3d 251, the plaintiff filed an action to set aside a trustee's sale, alleging that the defendant, who held a note secured by plaintiff's property, fraudulently induced her to default on the note. In a prior unlawful detainer action that resulted in the plaintiff's eviction, she unsuccessfully asserted the same claim of fraud as an affirmative defense. Vella stated: "The sparse record presented to us fails to show either the precise nature of the factual issues litigated in the other proceeding, or the depth of the court's inquiry. . . .In the absence of a record establishing that the claim was asserted and that the legal and factual issues therein were fully litigated, we conclude that the question of fraudulent acquisition of title was not foreclosed by the adverse judgment in the earlier summary proceeding." ( Id. at p. 258.)