Hatler
Hatler v. Tuolomne County
Opinion
Lead Opinion
MEMORANDUM *
Stewart Hatler appeals from the district court’s ruling that his federal claims were barred by collateral estoppel. The facts and prior proceedings are known to the parties, and are restated here only as needed.
I
Hatler contends that the district court erred in concluding that collateral estoppel barred him from pursuing his federal claims. Federal courts may give preclusive effect to the findings of state administrative bodies as a matter of federal common law. Univ. of Tenn. v. Elliott, 478 U.S. 788, 794 , 106 S.Ct. 3220 , 92 L.Ed.2d 635 (1986). But before giving unreviewed administrative decisions preclusive effect, federal courts must first ensure that the so-called “Utah Construction” factors are met-i.e., that the administrative body “ ‘[1] acted in a judicial capacity ... [2] resolved disputed issues of fact properly before it ... [and][3] the parties ... had an adequate opportunity to litigate.’ ” Elliot, 478 *973 U.S. at 800 , 106 S.Ct. 3220 (quoting U.S. v. Utah Constr. & Mining Co., 384 U.S. 394, 422 , 86 S.Ct. 1545 , 16 L.Ed.2d 642 (1966)). We have also recognized that, in light of California’s adoption of the Utah Construction standard, the only…