## Facts

- Monroe Dyson worked as a youth counselor at the Preston School of Industry within the California Department of the Youth Authority.
- Preston’s Chief of Security, Thomas Gold, received information from Dyson’s estranged wife alleging Dyson was stealing Preston property and keeping it at his home.
- Gold initiated a search of Dyson’s residence and enlisted sheriff’s deputies to assist; Preston personnel participated in the search and seizure.
- Items seized included Preston property (including T-shirts and intercoms) that were provided to law enforcement and used to support a criminal prosecution.
- In the criminal case, a court suppressed the evidence and dismissed the prosecution after finding the search violated Dyson’s constitutional right to privacy.
- The State Personnel Board later obtained the same physical evidence and admitted it in an administrative disciplinary proceeding, then upheld Dyson’s dismissal based largely on that evidence.
- The superior court denied Dyson’s request for mandate relief and affirmed the Board’s decision, and Dyson appealed.

## Issues

1. Whether the State Personnel Board was collaterally estopped from disputing the criminal court’s determination that the search of Dyson’s residence was unconstitutional.
2. Whether the exclusionary rule required suppression, in a state administrative disciplinary hearing, of evidence obtained through an unconstitutional search in which the employing agency was significantly involved.

## Decision

- The Court of Appeal reversed the judgment upholding the Board’s decision.
- The court held the Board was collaterally estopped from denying the search’s constitutional invalidity as determined in the prior criminal proceeding.
- The court held the exclusionary rule applied on these facts, barring use of the unconstitutionally obtained evidence in the administrative disciplinary hearing.
- The matter was returned for further proceedings consistent with the opinion, without reliance on the tainted evidence.

## Legal Principles

- Collateral estoppel bars relitigation of an issue actually litigated and finally decided when the later proceeding involves the same issue and the relevant governmental interests are sufficiently identical.
- A criminal court’s final suppression determination on the illegality of a government search may bind a state administrative agency in a later disciplinary matter arising from the same search.
- The exclusionary rule may apply in administrative disciplinary proceedings when exclusion would meaningfully deter governmental misconduct, particularly where the public employer initiated or actively participated in the unconstitutional search and seeks to benefit from its fruits.
- Application of the exclusionary rule in administrative settings depends on context, including the employer’s role in the unlawful conduct and the connection between the illegality and the evidence offered.

## Conclusion

The court held that the Board could not relitigate a criminal court’s final ruling that the employer-involved search was unconstitutional, and that the resulting evidence had to be excluded from the employee’s administrative dismissal hearing because excluding it served deterrence and protected judicial integrity.


Dyson v. State Personnel Bd., 213 Cal. App. 3d 711, 262 Cal. Rptr. 112 (Ct. App. 3d Dist. 1989)