issue preclusion doctrine in California

2021The preclusive effect of the administrative findings i. Claim preclusion “Generally speaking, if a complainant fails to overturn an adverse administrative decision by writ of mandate, ‘and if the administrative proceeding possessed the requisite judicial character [citation], the administrative decision is binding in a later civil action brought in superior court.’” (Runyon v. Board of Trustees of California State University (2010) 48 Cal.4th 760, 773 .) The binding nature of a final administrative decision is typically understood as referring to the doctrine of issue preclusion (see, e.g., Mu

2017Co., supra, 40 Cal.App.2d at p. 628 relied on to find issue preclusion applicable to questions expressly not reached by the appellate court), the Restatement Second provides, if a judgment rendered by a court of first instance on alternative grounds is upheld by the appellate court on only one of the grounds, and the appellate court “ ‘refuses to consider whether or not the other [ground] is sufficient and accordingly affirms the judgment, the judgment is conclusive [only] as to the first determination.’ ” (Newport Beach, at p. 1129, quoting Rest.2d Judgments, § 27, com. o.) 6 *809 Observing t

2021Because we conclude Family Health’s collateral estoppel argument fails on the merits, we deny the request for judicial notice as unnecessary to the disposition of this appeal. 11 technical requirements are all met, the doctrine is to be applied ‘only where such application comports with fairness and sound public policy.’ ” ’ ” (Union Pacific Railroad Co. v. Santa Fe Pacific Pipelines, Inc. (2014) 231 Cal.App.4th 134, 185 .) Thus, a court must consider whether application of the issue preclusion doctrine would comport with the doctrine’s core policies, namely the preservation of the integrity o

2021Because we conclude Family Health’s collateral estoppel argument fails on the merits, we deny the request for judicial notice as unnecessary to the disposition of this appeal. 11 technical requirements are all met, the doctrine is to be applied ‘only where such application comports with fairness and sound public policy.’ ” ’ ” (Union Pacific Railroad Co. v. Santa Fe Pacific Pipelines, Inc. (2014) 231 Cal.App.4th 134, 185 .) Thus, a court must consider whether application of the issue preclusion doctrine would comport with the doctrine’s core policies, namely the preservation of the integrity o

2021As we noted in Key v. Tyler II, the Invalidity Ruling consists of a 67-page statement of decision “containing a detailed collection of findings.” (Key v. Tyler II, supra, 34 Cal.App.5th at p. 534 .) We further explained that “[n]ot every interpretation of every item of evidence discussed in Judge Goetz’s description of her findings is necessarily binding under the doctrine of issue preclusion.” (Ibid.) Rather, only findings that were “ ‘not . . . “. . .unnecessary” ’ ” to the court’s decision are binding.

2021As we noted in Key v. Tyler II, the Invalidity Ruling consists of a 67-page statement of decision “containing a detailed collection of findings.” (Key v. Tyler II, supra, 34 Cal.App.5th at p. 534 .) We further explained that “[n]ot every interpretation of every item of evidence discussed in Judge Goetz’s description of her findings is necessarily binding under the doctrine of issue preclusion.” (Ibid.) Rather, only findings that were “ ‘not . . . “. . .unnecessary” ’ ” to the court’s decision are binding.

2024Issue Preclusion The doctrine of issue preclusion or collateral estoppel “ ‘precludes relitigation of issues argued and decided in prior proceedings.’ ” (Mycogen Corp. v. Monsanto Co. (2002) 28 Cal.4th 888, 896 ; Williams v. Doctors Medical Center of Modesto, Inc. (2024) 100 Cal.App.5th 1117 , 1131.) In order for issue preclusion to apply, the following elements must be met: (1) the issue sought to be precluded from relitigation must be identical to that decided in a former proceeding; (2) the issue must have been actually litigated in the former proceeding; (3) the issue must have been necess

2022“Collateral estoppel, or issue preclusion, ‘precludes relitigation of issues argued and decided in prior proceedings.’ [Citation.]” (Mycogen Corp. v. Monsanto Co. (2002) 28 Cal.4th 888, 896-897 , fn. omitted.) Under either the principle that one judge cannot overturn an interim ruling of another judge, or under the doctrine of issue preclusion, Judge Singley’s ruling that the Lebanese marriage was void was proper.

2016(Boeken v. Philip Morris USA, Inc. (2010) 48 Cal.4th 788, 797 .) In addition, the doctrine of issue preclusion (i.e., direct and collateral estoppel) requires the following elements: “First, the issue sought to be precluded from relitigation must be identical to that decided in a former proceeding.

2015(Boeken v. Philip Morris USA, Inc. (2010) 48 Cal.4th 788, 797 ; Pitzen v. Superior Court, supra, 120 Cal.App.4th at p. 1384 .) There is no information in the record showing the identical issue was raised and determined in the prior small claims action.

2013Issue preclusion prevents "relitigation of issues argued and decided in prior proceedings." (Lucido v. Superior Court (1990) 51 Cal.3d 335, 341 (Lucido); Castillo, supra, 92 Cal.App.4th at p. 481 .) To apply this issue preclusion doctrine in a given case, the courts inquire if (1) the issue was identical to that decided in the former proceeding, (2) the issue was actually litigated previously, (3) the issue was necessarily decided previously, (4) the previous 9 decision has become final and was on the merits, and (5) the person previously involved was a party or in privity with a party to the

2013Issue preclusion prevents "relitigation of issues argued and decided in prior proceedings." (Lucido v. Superior Court (1990) 51 Cal.3d 335, 341 (Lucido); Castillo, supra, 92 Cal.App.4th at p. 481 .) To apply this issue preclusion doctrine in a given case, the courts inquire if (1) the issue was identical to that decided in the former proceeding, (2) the issue was actually litigated previously, (3) the issue was necessarily decided previously, (4) the previous 9 decision has become final and was on the merits, and (5) the person previously involved was a party or in privity with a party to the

2025(City of Sacramento v. State of California (1990) 50 Cal.3d 51, 64 .) The two exceptions are distinct from one another.

2024(City of Sacramento v. State of California (1990) 50 Cal.3d 51, 64 .) The two exceptions are distinct from one another.

2025(Curiel, supra, 15 Cal.5th at pp. 453-454.) The law of the case doctrine is “related” to issue preclusion, though it “has to do with the legal principles governing a particular case in subsequent proceedings following an appeal.” (People v. Beaudreaux, supra, 100 Cal.App.5th at p. 1240, fn. 4, emphasis in original.) It provides that “a principle or rule that a reviewing court states in an opinion and that is necessary to the reviewing court’s decision must be applied throughout all later proceedings in the same case, both in the trial court and on a later appeal.” (People v. Jurado (2006) 38 C

2024This is consistent with the statute’s overall purpose: to ensure that murder culpability is commensurate with a person’s actions, while also ensuring that clearly meritless petitions can be efficiently addressed as part of a single-step prima facie review process.’” ( Curiel, supra, 15 Cal.5th at pp. 9 463-464, quoting Lewis, supra, 11 Cal.5th at p. 971 .) The record of conviction generally includes appellate opinions (Lewis, supra, 11 Cal.5th at p. 972 ), and the court may consider the procedural history of the case recited therein, though not the factual summary. (§ 1172.6, subd. (d)(3); Peo

2024(Strong, at p. 717.) As the Supreme Court later indicated in Curiel, the test is whether there has been a change so significant that it would result in a different factual finding on the issue claimed to be foreclosed had the law as it exists petitions, a rule with many complexities particular to the law of habeas corpus (see In re Reno (2012) 55 Cal.4th 428 , 449–453; In re Clark (1993) 5 Cal.4th 750 , 767–770; cf. In re Friend (2021) 11 Cal.5th 720, 728, 737 [construing a statute that codifies the bar against successive habeas petitions in capital cases]), may be equated with the doctrine of

2024(Strong, at p. 717.) As the Supreme Court later indicated in Curiel, the test is whether there has been a change so significant that it would result in a different factual finding on the issue claimed to be foreclosed had the law as it exists petitions, a rule with many complexities particular to the law of habeas corpus (see In re Reno (2012) 55 Cal.4th 428 , 449–453; In re Clark (1993) 5 Cal.4th 750 , 767–770; cf. In re Friend (2021) 11 Cal.5th 720, 728, 737 [construing a statute that codifies the bar against successive habeas petitions in capital cases]), may be equated with the doctrine of

2024We independently review the denial of a resentencing petition at the prima facie stage, whether the denial is based on the issue preclusion doctrine (Cheveldave v. Tri Palms Unified Owners Assn. (2018) 27 Cal.App.5th 1202 , 1218–1219), the law of the case doctrine (Leider v. Lewis (2017) 2 Cal.5th 1121, 1125, 1127 ), or, more generally, failure by the petitioner to make a prima facie showing under section 1172.6 (People v. Harden (2022) 81 Cal.App.5th 45 , 52). 11 D.

2024We independently review the denial of a resentencing petition at the prima facie stage, whether the denial is based on the issue preclusion doctrine (Cheveldave v. Tri Palms Unified Owners Assn. (2018) 27 Cal.App.5th 1202 , 1218–1219), the law of the case doctrine (Leider v. Lewis (2017) 2 Cal.5th 1121, 1125, 1127 ), or, more generally, failure by the petitioner to make a prima facie showing under section 1172.6 (People v. Harden (2022) 81 Cal.App.5th 45 , 52). 11 D.

2024(Strong, at p. 717.) As the Supreme Court later indicated in Curiel, the test is whether there has been a change so significant that it would result in a different factual finding on the issue claimed to be foreclosed had the law as it exists petitions, a rule with many complexities particular to the law of habeas corpus (see In re Reno (2012) 55 Cal.4th 428 , 449–453; In re Clark (1993) 5 Cal.4th 750 , 767–770; cf. In re Friend (2021) 11 Cal.5th 720, 728, 737 [construing a statute that codifies the bar against successive habeas petitions in capital cases]), may be equated with the doctrine of

2024(Strong, at p. 717.) As the Supreme Court later indicated in Curiel, the test is whether there has been a change so significant that it would result in a different factual finding on the issue claimed to be foreclosed had the law as it exists petitions, a rule with many complexities particular to the law of habeas corpus (see In re Reno (2012) 55 Cal.4th 428 , 449–453; In re Clark (1993) 5 Cal.4th 750 , 767–770; cf. In re Friend (2021) 11 Cal.5th 720, 728, 737 [construing a statute that codifies the bar against successive habeas petitions in capital cases]), may be equated with the doctrine of

2023(United Bank Trust Co. of California v. Hunt (1934) 1 Cal.2d 340, 345 .) But Turner cites no authority to support his contention that defendants cannot prevail by virtue of the doctrine of issue preclusion, and there are cases to the contrary.

2023(United Bank Trust Co. of California v. Hunt (1934) 1 Cal.2d 340, 345 .) But Turner cites no authority to support his contention that defendants cannot prevail by virtue of the doctrine of issue preclusion, and there are cases to the contrary.

2023However, the courts of appeal have held that it can.15 (E.g., People v. Lopez (2022) 78 Cal.App.5th 1 , 14; 15 The only disagreement was as to whether a jury’s finding that a petitioner was a “major participant” and acted “with reckless indifference to human life” was conclusive even after the Supreme Court’s decisions in People v. Banks (2015) 61 Cal.4th 788 (Banks) and People v. Clark (2016) 63 Cal.4th 522 (Clark), which clarified [footnote continued on next page] 36 People v. Farfan (2021) 71 Cal.App.5th 942 , 953-956; People v. Daniel (2020) 57 Cal.App.5th 666 , 678, review granted Feb. 24

2023In Strong, we applied “one well-settled equitable exception to the general rule” of issue preclusion, which “holds that preclusion does not apply when there has been a significant change in the law since the factual findings were rendered that warrants reexamination of the issue.” (Strong, supra, 13 Cal.5th at p. 716 .) “This exception ensures basic fairness by allowing for relitigation where ‘the change in the law [is] such that preclusion would result in a manifestly inequitable administration of the laws.’ [Citation.] It also reflects a recognition that in the face of this sort of legal cha

2023(CVMT 2014, supra, 231 Cal.App.4th at p. 908 ; CVMT 2020, supra, D074339.) We also imposed sanctions on Corrales in the second of those lawsuits for filing an objectively frivolous appeal, which lacked merit due to the issue preclusion and claim preclusion that arose from CVMT 2014.

2023(CVMT 2014, supra, 231 Cal.App.4th at p. 908 ; CVMT 2020, supra, D074339.) We also imposed sanctions on Corrales in the second of those lawsuits for filing an objectively frivolous appeal, which lacked merit due to the issue preclusion and claim preclusion that arose from CVMT 2014.

2023However, the courts of appeal have held that it can.15 (E.g., People v. Lopez (2022) 78 Cal.App.5th 1 , 14; 15 The only disagreement was as to whether a jury’s finding that a petitioner was a “major participant” and acted “with reckless indifference to human life” was conclusive even after the Supreme Court’s decisions in People v. Banks (2015) 61 Cal.4th 788 (Banks) and People v. Clark (2016) 63 Cal.4th 522 (Clark), which clarified [footnote continued on next page] 36 People v. Farfan (2021) 71 Cal.App.5th 942 , 953-956; People v. Daniel (2020) 57 Cal.App.5th 666 , 678, review granted Feb. 24

2023In Strong, we applied “one well-settled equitable exception to the general rule” of issue preclusion, which “holds that preclusion does not apply when there has been a significant change in the law since the factual findings were rendered that warrants reexamination of the issue.” (Strong, supra, 13 Cal.5th at p. 716 .) “This exception ensures basic fairness by allowing for relitigation where ‘the change in the law [is] such that preclusion would result in a manifestly inequitable administration of the laws.’ [Citation.] It also reflects a recognition that in the face of this sort of legal cha

2022Relying largely on the issue-preclusion analysis in a recent duty-to- defend case, Textron Inc. v. Travelers Casualty & Surety Co. (2020) 45 Cal.App.5th 733 , the Thompsons contend that whether any of their potential liability to SLT arose from an “accident” differs from issues 4 The Thompsons also note that “ ‘a particular danger of injustice arises’ ” if a nonparty to the prior action invokes issue preclusion, so such cases “ ‘require close examination to determine whether nonmutual use of the doctrine is fair and appropriate.’ ” (Bostick, supra, 147 Cal.App.4th at p. 97 .) But they identify

2022Relying largely on the issue-preclusion analysis in a recent duty-to- defend case, Textron Inc. v. Travelers Casualty & Surety Co. (2020) 45 Cal.App.5th 733 , the Thompsons contend that whether any of their potential liability to SLT arose from an “accident” differs from issues 4 The Thompsons also note that “ ‘a particular danger of injustice arises’ ” if a nonparty to the prior action invokes issue preclusion, so such cases “ ‘require close examination to determine whether nonmutual use of the doctrine is fair and appropriate.’ ” (Bostick, supra, 147 Cal.App.4th at p. 97 .) But they identify

2022(SCERS, supra, 195 Cal.App.4th at p. 452 .) But Ledesma did not change the law in a respect that is material here.

2022(SCERS, supra, 195 Cal.App.4th at p. 452 .) But Ledesma did not change the law in a respect that is material here.

2022For this proposition, the Thompsons cite Semtek International Inc. v. Lockheed Martin Corp. (2001) 531 U.S. 497 , 507 and this court’s opinion in Guerrero v. Department of Corrections (2018) 28 Cal.App.5th 1091, 1100 .

2022For this proposition, the Thompsons cite Semtek International Inc. v. Lockheed Martin Corp. (2001) 531 U.S. 497 , 507 and this court’s opinion in Guerrero v. Department of Corrections (2018) 28 Cal.App.5th 1091, 1100 .

2022For this proposition, the Thompsons cite Semtek International Inc. v. Lockheed Martin Corp. (2001) 531 U.S. 497 , 507 and this court’s opinion in Guerrero v. Department of Corrections (2018) 28 Cal.App.5th 1091, 1100 .

2022For this proposition, the Thompsons cite Semtek International Inc. v. Lockheed Martin Corp. (2001) 531 U.S. 497 , 507 and this court’s opinion in Guerrero v. Department of Corrections (2018) 28 Cal.App.5th 1091, 1100 .