California, United States of America
The following excerpt is from Orrick v. San Joaquin Community Hosp., 62 Cal.App.4th 1466, 73 Cal.Rptr.2d 757 (Cal. App. 1998):
"For purposes of identifying a cause of action under the doctrine of res judicata, 'California has consistently applied the "primary rights" theory, under which the invasion of one primary right gives rise to a single cause of action' [Citation.] But ' the "cause of action" is based upon the harm [62 Cal.App.4th 1475] suffered, as opposed to the particular theory asserted by the litigant. [Citation.] Even where there are multiple legal theories upon which recovery might be predicated, one injury gives rise to only one claim for relief.' [Citation.]" (Branson v. Sun-Diamond Growers (1994) 24 Cal.App.4th 327, 340-341, 29 Cal.Rptr.2d 314, fn. omitted.)
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