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Andrews v. Agricultural Labor Relations Board

California Supreme Court

623 P.2d 151 (1981)

Facts

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

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Issue

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Holding and Reasoning (Mosk, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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