Basurto v. Imperial Irrigation District
150 Cal. Rptr. 3d 145
Cal. Ct. App.2012Background
- Basurto was discharged by the District after a March 31, 2003 accident in which alcohol was involved; BAC at 0.031%.
- District Board upheld discharge after internal grievance proceedings; Basurto challenged via a writ of mandate and civil complaint.
- A 2007 second District Board hearing occurred with new members; Basurto did not raise discrimination or due-process claims there.
- The trial court granted summary judgment, applying collateral estoppel and res judicata under Johnson and Takahashi.
- On appeal, Basurto contends the internal procedures lack a judicial character; court affirms collateral estoppel and the sufficiency of proceedings.
- The court holds the APA does not apply to irrigation districts and that the second hearing satisfied due process and impartiality.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the District Board decision can bar Basurto's civil claims via collateral estoppel/res judicata. | Basurto argues the Board lacked a true judicial forum to preclude later claims. | District asserts the internal hearing was quasi-judicial and afforded due process. | Collateral estoppel bar affirmed; proceeding had quasi-judicial character. |
| Whether the APA applies to the District's internal grievance procedures. | Basurto contends APA procedures should govern. | APA does not apply to local agencies like irrigation districts. | APA does not apply; district procedures suffice. |
| Whether the District Board was inherently biased, undermining impartiality for collateral estoppel. | Basurto claims inherent bias due to potential financial impact on the District. | Board members denied conflicts; no evidence of actual bias. | Board impartial; bias not shown. |
| Whether Basurto exhausted his due-process claims at the administrative hearing to permit collateral estoppel. | Basurto argues due-process issues could survive but were not raised. | Basurto waived due-process issues by not raising them at the hearing. | Waiver upheld; collateral estoppel valid. |
Key Cases Cited
- Johnson v. City of Loma Linda, 24 Cal.4th 61 (2000) (administrative findings bar FEHA claims when not set aside via judicial review)
- Takahashi v. Board of Education, 202 Cal.App.3d 1464 (1988) (res judicata and administrative review bar later civil actions; full opportunity to raise defenses)
- Sims v. Department of Social Services, 32 Cal.3d 468 (1982) (administrative hearings with due process can have collateral estoppel effect)
- Castillo v. City of Los Angeles, 92 Cal.App.4th 477 (2001) (identical issues and final administrative findings can bar FEHA claims)
- Lucido v. Superior Court, 51 Cal.3d 335 (1990) (threshold elements of collateral estoppel)
- Pacific Lumber Co. v. State Water Resources Control Bd., 37 Cal.4th 921 (2006) (administrative findings can be final on the merits where applicable)
- McDonald v. Antelope Valley Community College Dist., 45 Cal.4th 88 (2008) (agency internal procedures can suffice for quasi-judicial determinations)