Court: Court of Appeals for the Ninth Circuit; January 31, 2002; Federal Appellate Court
The memorandum addresses the applicability of res judicata in the context of claims made by the Motel Owners against both the City and the County Defendants. The court reviews the summary judgment on res judicata grounds de novo, focusing on whether the Planning Commission's hearings have claim-preclusive effect in federal court. It notes that the district court's decision relied solely on the Utah Construction test, which is a preliminary analysis. Following this test, state law governs preclusion, requiring federal courts to give agency decisions the same effect as they would receive in state courts.
In California, administrative estoppel law parallels the Utah Construction test but adds a requirement that agency adjudications must meet traditional claim preclusion criteria to have preclusive effect. The law is flexible, indicating that not all agency decisions automatically carry res judicata effect and that some may be subject to relaxed rules. Consequently, the Motel Owners' 1983 action is unlikely to be barred in California courts, even if the relevant tests are satisfied. Their administrative mandamus review only carries issue-preclusive effect, limiting the extent to which issues can be re-litigated but not barring the entire lawsuit.
Furthermore, the Commission's hearings do not have res judicata effect because the resolutions stemming from those hearings merely reaffirmed existing permit terms, not depriving the Motel Owners of any rights. Therefore, the district court's summary judgment in favor of the City stands on different grounds, despite the lack of res judicata effect.
Regarding the County Defendants, res judicata also does not bar the Motel Owners' claims for similar reasons as with the City. Nonetheless, the district court's summary judgment for the County Defendants is upheld due to Deputy Walker's qualified immunity. He is protected unless he violated clearly established rights that a reasonable person would recognize, particularly when acting in reliance on established statutes or ordinances, although the existence of such statutes isn't solely determinative.
Qualified immunity does not apply to a public official enforcing a statute that clearly violates fundamental constitutional principles. In this case, the resolution enacted by Bellflower was not deemed patently unconstitutional, despite its potential vulnerability under New York v. Burger; it was not obviously unconstitutional. Deputy Walker's enforcement of the permit conditions was reasonable, especially since Mr. Peng had consented to those conditions, justifying summary judgment in favor of Deputy Walker on qualified immunity grounds.
Regarding the Monell claim against Sheriff Block, Solano County cannot be held liable under Section 1983 based solely on respondeat superior. Liability arises only if there is evidence of an official policy or custom that led to a constitutional rights deprivation. The Motel Owners failed to establish a direct causal link between the County's policy of enforcing the Bellflower Municipal Code (BMC) and any alleged Fourth Amendment violation. The claim that the Motel Owners’ rights were infringed was attributed to a resolution from Bellflower’s Planning Commission, not the Sheriff's enforcement of the BMC. Additionally, there was no evidence supporting a failure to train claim for Monell liability. Thus, summary judgment in favor of the County was affirmed. The court's disposition is not suitable for publication or citation, except as permitted under Ninth Circuit Rule 36-3.
In Plaine v. McCabe, the Ninth Circuit clarifies the process for determining whether state agency decisions have preclusive effects in federal statute cases, specifically regarding § 1983 claims. The analysis begins with assessing Congressional intent for agency decisions to be preclusive, as established in Astoria, but is omitted here since the Supreme Court has confirmed such intent for § 1983 claims in University of Tennessee v. Elliott. The court also references a two-part test from the California Supreme Court used to evaluate the preclusive effect of state administrative determinations. The Utah Construction and Elliott frameworks are noted to apply to both issue and claim preclusion in administrative adjudications. Additionally, the excerpt discusses various California cases pertaining to the elements of collateral estoppel and res judicata. It emphasizes that administrative mandamus actions are treated as special proceedings, which only carry issue-preclusive, not claim-preclusive, effects. The court retains the authority to affirm lower court decisions based on any record-supported ground. The excerpt concludes with a reference to a case where a plaintiff had no § 1983 cause of action against a county due to lack of legal causation for his injury.
