Johnson v. City of Loma Linda

In Westlake Community Hosp. v. Superior Court (1976) 17 Cal.3d 465, 484 [ 131 Cal.Rptr. 90 , 551 P.2d 410 ], we held that unless a party to a quasi-judicial administrative agency proceeding challenges the adverse findings made in that proceeding, by means of a mandate action in superior court, those findings are binding in later civil actions.

Does that holding apply to a city employee’s discrimination claims under the California Fair Employment and Housing Act (FEHA) (Gov. Code, § 12900 et seq.) and under title VII of the federal Civil Rights Act of 1964 (Title VII) (42 U.S.C. § 2000e et seq.), when the employee fails to have the city’s final adverse finding judicially reviewed and set aside? The answer is “yes” as to claims under California’s FEHA but “no” as to claims under Title VII of the federal act.

We also hold that a trial court’s summary judgment based on the defense of laches must be reviewed de novo.

I.

Our account of the facts is taken from the record before the trial court when it granted defendant’s motion for summary judgment. (Flatt v. Superior Court (1994) 9 Cal.4th 275, 279 [ 36 Cal.Rptr.2d 537 , 885 P.2d 950 ].) We review the trial court’s decision…

On the viability of plaintiff’s cause of action for violation of the Fair Employment and Housing Act (FEHA) (Gov. Code, § 12900 et seq.), I would reach the same result as the majority, but would employ a less confusing and more clearly applicable legal theory. Rather than rely on a “requirement of exhaustion of judicial remedies” (maj. opn., ante, at p. 70), assertedly articulated in Westlake Community Hosp. v. Superior Court (1976) 17 Cal.3d 465 [ 131 Cal.Rptr. 90 , 551 P.2d 410 ] (Westlake), I would rest our decision on the collateral estoppel effect of a final administrative finding made in a quasi-judicial proceeding (People v. Sims (1982) 32 Cal.3d 468 [ 186 Cal.Rptr. 77 , 651 P.2d 321 ] (Sims)).

In Sims , this court dispelled the “uncertainty and confusion existing] in the case law as to whether the decisions of an administrative agency may ever collaterally estop a later action.” (Sims, supra, 32 Cal.3d at p. 477 .) Guided by a United States Supreme Court decision addressing the same question (United States v. Utah Constr. Co. (1966) 384 U.S. 394 [ 86 S.Ct. 1545 , 16 L.Ed.2d 642 ]), we held administrative agency findings may be given collateral estoppel effect if the…

In Westlake Community Hosp. v. Superior Court (1976) 17 Cal.3d 465, 484 , 131 Cal.Rptr. 90 , 551 P.2d 410 , we held that unless a party to a quasi-judicial administrative agency proceeding challenges the adverse findings made in that proceeding, by means of a mandate action in superior court, those findings are binding in later civil actions.

Does that holding apply to a city employee's discrimination claims under the California Fair Employment and Housing Act (FEHA)(Gov.Code, § 12900 et seq.) and under title VII of the federal Civil Rights Act of 1964 (Title VII) (42 U.S.C. § 2000e et seq.), when the employee fails to have the city's final adverse finding judicially reviewed and set aside? The answer is "yes" as to claims under California's FEHA but "no" as to claims under Title VII of the federal act.

We also hold that a trial court's summary judgment based on the defense of laches must be reviewed de novo.

Our account of the facts is taken from the record before the trial court when it granted defendant's motion for summary judgment. ( Flatt v. Superior Court (1994) 9 Cal.4th 275, 279 , 36 Cal. Rptr.2d 537 , 885 P.2d 950 .) We review the trial court's decision…