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Jeffreys v. Griffin10/31/2002
evidence . . . establishes that claimant lost his employment for [possessing] company property (*16)without authorization [and therefore] he lost his employment due to misconduct in connection therewith" (at 498). During the administrative proceedings, the criminal charges against Ryan were adjourned in contemplation of dismissal and then dismissed in the interest of justice.
Thereafter, Ryan commenced a civil action for false arrest, malicious prosecution, slander, wrongful discharge and resultant injuries to Ryan's wife. The defendants pled a defense of res judicata and collateral estoppel on the basis of the prior administrative determination denying Ryan's claim for unemployment benefits. In reversing and granting the defendants' motion to dismiss, the Court of Appeals held that ". . . the doctrines of res judicata and collateral estoppel are applicable to give conclusive effect to the quasi-judicial determinations of administrative agencies . . . when rendered pursuant to the adjudicatory authority of an agency to decide cases brought before its tribunals employing procedures substantially similar to those used in a court of law . . . .` uch determinations, when final, become conclusive and binding on the courts' (citations omitted)" (Ryan v New York Telephone, 62 NY2d at 499). As can be seen from Ryan, (1) accusations of criminal conduct, (2) absence of counsel, (3) unavailability of disclosure afforded under the CPLR, (4) the fact that the rules of evidence are not as strictly applied in an agency hearing as they are in court, and (5) the relationship between civil and criminal proceedings are not grounds for denying issue preclusive effect to administrative proceedings. There is also nothing in Ryan or subsequent Court of Appeals decisions which considers the professional status of a party as a rationale for creating a special rule.
Four years after Ryan, the Court of Appeals decided three other cases applying the doctrine of collateral estoppel (issue preclusion) to a prior administrative determination. They are: Allied Chemical v Niagara Mohawk Power Corporation (72 NY2d 271, cert denied 488 US 1005); Staatsburg Water Company v Staatsburg Fire District (72 NY2d 147); and Halyalkar v Board of Regents of State of New York (72 NY2d 261).
Allied made a contract with Niagara Mohawk (NM), the (*17)utility, to sell it electricity at a specified rate, but the contract also provided that either party was entitled to have the contract superseded by new rates should such be set by the Public Service Commission.
The PSC set new rates and a dispute arose as to whether Allied's type of facility fell within the new rates. NM brought a proceeding before the Public Service Commission for a declaration that Allied should pay the new higher rates. The PSC ruled for NM. Allied then brought a contract action against NM, which then moved for and was granted summary judgment against Allied in favor of NM, finding that collateral estoppel applied to preclude Allied.
In Allied, the Court of Appeals (at 276-277) refers to the "beguilingly simple prerequisite that the administrative decision be `quasi-judicial' in character." The court notes that this involves "a multifaceted inquiry." This amounts to a full and fair opportunity test. The court stresses that "the expectation of the parties is important in determining the fairness"; and then appears to find that this is its principal reason for sustaining the Allied estoppel.
In Staatsburg, however, the motion based on collateral estoppel failed. The plaintiff was a water utility which regulated rates. It sold water to the defendant, a fire district, which later stopped paying because of allegedly inadequate
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