GENERAL LEGAL PRINCIPLES; COLLATERAL ESTOPPEL; RES JUDICATA – Type or Nature of Prior Proceeding

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1405.00000 – GENERAL LEGAL PRINCIPLES; COLLATERAL ESTOPPEL; RES JUDICATA
1405.02000 – Type or Nature of Prior Proceeding

Collateral estoppel may apply to an administrative agency’s decision only if the agency acted in a neutral, judicial capacity to decide an issue over which it had jurisdiction. (Noble v. Draper (2008) 160 Cal.App.4th 1, 10; see also Healdsburg Union High School District (1997) PERB Decision No. 1185, adopting proposed decision at p. 51 [even assuming a third-party hearing officer was neutral, collateral estoppel cannot apply where hearing officer’s decision is subject to review by non-neutral entity, irrespective of whether that entity adopts the hearing officer’s decision].) Moreover, collateral estoppel is a discretionary doctrine that need not apply where application would fail to promote judicial or administrative economy, protect litigants from vexatious litigation, and/or otherwise preserve fairness and integrity in the administration of justice. (Castillo v. City of Los Angeles (2001) 92 Cal.App.4th 477, 481 & 483.) (pp. 24-25.)