## Facts

- Mitsue Takahashi was a tenured teacher employed by the Livingston Union School District from 1960 until her termination in 1980.
- In 1978, the district evaluated Takahashi and identified serious performance deficiencies, including classroom management, warning that lack of improvement could lead to dismissal proceedings.
- Following statutory procedures, a Commission on Professional Competence conducted a dismissal hearing and ordered Takahashi’s dismissal.
- Takahashi sought judicial review of the dismissal through a mandate proceeding challenging the termination under the California Education Code; she did not plead civil-rights or constitutional claims.
- The mandate action resulted in a final judgment upholding the dismissal, which was affirmed on appeal.
- Takahashi later filed separate lawsuits asserting (1) common-law tort-type claims (including emotional distress) and (2) civil-rights claims arising from the same dismissal and related conduct, naming the district, the board, and individual officials.
- The trial court consolidated the later actions and granted summary judgment for defendants on res judicata grounds.

## Issues

1. Whether the prior final mandate judgment upholding Takahashi’s dismissal barred later common-law and civil-rights claims arising from the same termination under California’s primary-rights doctrine.
2. Whether claim preclusion applied to individual district officials not formally named in the earlier mandate action based on privity with the district and board.
3. Whether pursuing teacher-dismissal procedures and mandate review foreclosed later litigation framed under FEPA-related or civil-rights theories when the asserted injury flowed from the same termination.

## Decision

- The Court of Appeal affirmed the summary judgment for the district, board, and individual defendants.
- The court held the later tort and civil-rights causes of action were barred because they implicated the same primary right—continued public employment—previously adjudicated in the mandate proceeding.
- The court held claim preclusion extended to theories that were not pled earlier but were within the scope of the prior action and could have been raised.
- The court held the individual defendants were in privity with the public entity and board regarding acts taken in connection with the dismissal, so the prior judgment also barred claims against them.

## Legal Principles

- Under California’s primary-rights doctrine, a “cause of action” is defined by the invasion of a single primary right; different legal theories or remedies based on the same primary right constitute the same cause of action and must be brought together.
- A final judgment following mandate review of an administrative dismissal decision can have claim-preclusive effect over subsequent litigation arising from the same termination, including tort and civil-rights theories.
- Claim preclusion bars not only claims actually litigated but also claims that were within the scope of the prior action and could have been raised.
- Government officials sued for actions tied to an employment decision may be in privity with the governmental employer for res judicata purposes, allowing the earlier judgment for the entity to bar later suits against the individuals.

## Conclusion

Because Takahashi’s later common-law and civil-rights claims sought recovery for injuries caused by the same termination previously upheld in a final mandate judgment, the claims were precluded under California’s primary-rights doctrine, and the bar applied both to the public entities and to individual officials in privity with them.


Takahashi v. Bd. of Educ. of Livingston Union Sch. Dist., 202 Cal. App. 3d 1464, 249 Cal. Rptr. 578 (Ct. App. 1988)