Takahashi v. Board of Education

Mitsue Takahashi (plaintiff), a public-school teacher, was dismissed from her position by the Commission on Professional Competence (Commission) at an administrative termination hearing. The hearing occurred after Takahashi had been formally evaluated, counseled, and warned of her alleged deficiencies. Takahashi asserted numerous defenses at the hearing, but none based on violations of her civil or constitutional rights. After the hearing, Takahashi filed an action for a writ of mandate against the Commission alleging that she was wrongfully terminated in violation of the state education code. That action was dismissed and affirmed on appeal. Thereafter, Takahashi filed a second suit against the Commission and added individual defendants, and alleged various common-law causes of action. A few months later, Takahashi filed a third suit against the same defendants named in her second action and alleged civil-rights violations. Takahashi’s second and third actions were consolidated, and the defendants moved for summary judgment of all claims based on res judicata. The trial court granted the motion, noting that the issues in the consolidated action were or could have been litigated in the prior action. Takahashi appealed and argued that her second and third actions involved different primary rights from those asserted in her first action, and as to the individual-named defendants in her second and third actions, res judicata was not a viable defense because they were not parties to her first action.