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Andrews v. Agricultural Labor Relations Board
California Supreme Court
623 P.2d 151 (1981)
The Agricultural Labor Relations Board (ALRB) (plaintiff) initiated proceedings against Robert Andrews (defendant), an employer who had engaged in unfair labor practices against employees. The ALRB appointed Armando Menocal as a temporary administrative-law officer (ALO) to hear the case. Andrews learned just before the hearing that the ALO was an attorney who worked in employment discrimination on behalf of employees. At trial, the ALO consistently discounted evidence presented by Andrews yet accepted evidence presented by the employees. The ALO ultimately ruled in favor of the employees. Andrews moved for the ALO to be disqualified on the ground that the ALO was biased in favor of the employees. The motion was dismissed. Andrews appealed to the ALRB on the ground that the decision of the ALO had been biased. The ALRB rejected his claim, adopting the opinion of the ALO. Andrews appealed the case to the California Supreme Court.
Rule of Law
Holding and Reasoning (Mosk, J.)
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