Jackson v. City of Sacramento

The trial court decreed that a peremptory writ of mandate issue commanding defendants to accept a prior Workers’ Compensation Appeals Board decision as binding upon the issue of industrial causation of injuries in a hearing before the Retirement Hearing Commission of the Sacramento City Employees’ Retirement System. We conclude that the trial court erred in finding that collateral estoppel (or res judicata) is applicable. We explain later that while the trial court spoke of res judicata it is collateral estoppel with which we deal. Plaintiff claims a mental disability. We hold that no identity of issues exists where the retirement system, unlike the workers’ compensation statute, limits eligibility to physical disability. Accordingly, we reverse and remand the matter for trial.

Defendants City of Sacramento et al., appeal from a judgment of the Superior Court of Sacramento County in favor of plaintiff Ronald L. Jackson. Plaintiff cross-appeals from the judgment. On appeal defendants raise several contentions, including the one we find dispositive, that the trial court erred in applying the doctrine of collateral estoppel. Since we remand we do not reach other…