Li v. Super. Ct.
Annotate this CaseIn this writ proceeding, petitioner Quinn Li challenged the continued vitality of the "Chamberlain rule" (Chamberlain v. Ventura County Civil Service Com., 69 Cal.App.3d (1977)) claiming the California Supreme Court’s recent Conservatorship of O.B., 9 Cal.5th 989 (2020) decision impliedly abrogated Chamberlain’s long-standing interpretation of Code of Civil Procedure section 1094.5 (c). The Chamberlain rule held that the weight of the evidence phrase in subdivision (c) of section 1094.5 is synonymous with the preponderance of the evidence standard of proof. O.B. held that an appellate court applying the substantial evidence standard of review must account for the standard of proof required in the underlying proceeding when determining whether a finding is supported by the evidence. The Court of Appeal disagreed with petitioner’s implied abrogation argument but concluded, in sum, that a trial court reviewing an administrative agency’s findings under the independent judgment standard of review in section 1094.5 must, like under the substantial evidence standard of review, account for the standard of proof required and applied in the underlying proceeding. "We recognize this conclusion breaks with over four decades of established law. ... however, after closely reexamining the statutory construction employed by the Chamberlain and Ettinger courts, it is clear there is no basis for the interpretation that the weight of the evidence phrase in section 1094.5 is synonymous with preponderance of the evidence." Despite the significance of its conclusion on this important question of law, the Court denied petitioner’s petition for writ of mandate because he failed to raise any argument demonstrating the correct application of the standard of review would have resulted in a different outcome in the trial court. "Prejudicial error must be proven; it is not presumed."
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