Bixby v. Pierno

BURKE, J.

I concur in the majority opinion to the extent it would uphold the trial court’s refusal to exercise its independent judgment in reviewing the commissioner’s decision approving the recapitalization plan. However, rather than perpetuate the discredited1 line of cases which have *152heretofore precluded our trial courts from employing a uniform substantial evidence review of all administrative decisions, I submit that we should overrule those cases upon reexamining the constitutional and practical considerations which underlie them.

Briefly, the cases have developed the following rules applicable to the review of administrative decisions: Trial courts must exercise their own independent judgment, based upon the weight of the evidence, in reviewing those decisions of statewide, legislatively created administrative agencies which are claimed to have deprived petitioner of his “vested” or “constitutional” rights.2 However, the trial courts are permitted to employ an ordinary substantial evidence review of all other administrative decisions, including the rulings of “local” agencies3 and statewide agencies constitutionally empowered to exercise “judicial functions,”4 even if the agency decision had affected or annulled “vested” rights. Finally, on appeal from the trial court court’s decision based upon its exercise of independent judgment, the appellate courts must sustain the decision if it is supported by substantial evidence.5

Application of the foregoing rules has often resulted in seemingly anomalous decisions, the apparent by-product of a standard of administrative review made dependent upon the type of agency involved and the type of rights affected. Thus, the findings of a statewide, legislatively created agency in a license revocation case (i.e., involving “vested” rights) are subject to independent judgment review by the trial courts, although identical findings by a “local” or “constitutional” agency in such a case may be conclusive if based upon substantial evidence.6 Moreover, the *153findings of that same statewide, legislatively created agency in a license denial case also may be conclusive, since no “vested” rights are deemed to be involved.7

In addition to the apparent inconsistencies which have arisen under the rule of the foregoing cases, the courts have experienced difficulty in determining what rights are “vested” for purposes of applying that rule, with the result that decisions have been made on an undesirable “case-by-case” basis.8 Aside from distinguishing between license revocation and, license denial cases, this court has not attempted to establish any useful guidelines for the lower courts to follow, and the precedent value of our decisions in this area has been minimal.9 Furthermore, subsidiary problems have arisen in determining whether a particular agency falls within the “local” or “constitutional” categories, thereby permitting ordinary substantial evidence review.10

The majority opinion herein unfortunately enhances the confusion and uncertainty of earlier cases by introducing the further concept of “fundamental” rights. Under the majority’s approach, to require an independent judgment review not only must a right be “vested,” it must also be “fundamental” as well. The majority suggest that in determining whether or not a particular right is “fundamental,” the courts should “not alone weigh the economic aspect of it, but the effect of it in human terms and the importance of it to the individual in the life situation.” {Ante, p. 144.) If the single-factor “vested rights” test has led to confusion and anomaly, consider the difficulties which our trial and appellate courts will have in applying this new test, with its emphasis upon so-called “human terms” and “life situations.”

Similarly, the majority state that only a “substantial” effect upon “fundamental, vested rights” requires independent judgment view. The majority offers no standards or guidelines to assist the courts in determining whether a particular right has been “substantially” affected.

*154Finally, it is evident that the independent judgment test has proven undesirable and impractical in various respects. Although the cases which established the doctrine purported to create a corresponding presumption in favor of the correctness of administrative findings and conclusions,11 those cases also required the trial court to weigh the evidence and to exercise independent judgment in reviewing those findings and conclusions. Aside from the additional burden cast upon our trial courts in requiring them to perform this reweighing function, the foregoing requirements create conflicting standards and promote further uncertainty and lack of uniformity of decision, for to apply the presumption in favor of the administrative decision necessarily would diminish the independence of the trial courts’ review, although to disregard that presumption would ignore the expertise and discretion which, presumably, underlies any such decision.12

Turning to the constitutional principles which, according to Drummey and Laisne, supra, and the majority opinion herein, compel an independent judgment review, the first principle cited by these cases is the “separation of powers” doctrine. As stated by the court in Laisne, supra: “The powers of the government of the state are divided into three separate departments —the legislative, executive and judicial. (Article III, section 1, of the state Constitution.) State-wide judicial power may be exercised by only three enumerated courts, viz., the Supreme Court, the District Courts of Appeal, and the superior courts. (Article VI, section 1, of the state Constitution. ) No other body can exercise state-wide judicial power except as the result of constitutional amendment. [Citations.] If, therefore, some agency with state-wide judisdiction, other than one of the enumerated courts, without sanction by constitutional amendment, exercises or attempts to exercise judicial power, such action is in direct violation of the articles of the state Constitution cited above.

“. . . When one department or an agency thereof exercises the complete power that has been by the Constitution expressly limited to another, then such action violates the implied mandate of the Constitution. If, in the instant case, the superior court in the mandate proceedings were limited to the evidence presented before the board, or if the findings of fact by the board were conclusive on the court, then the board would be exercising the complete judicial power reserved to the enumerated courts. The appel*155lant’s right to practice optometry was a vested property right. [Citations.]” (19 Cal.2d at pp. 834-835.)

The dissent of Chief Justice Gibson in Laisne cited numerous cases from California and other jurisdictions rejecting the theory that the separation of powers doctrine prevents the exercise of quasi-judicial functions by administrative agencies.13

I do not quarrel with the premise that the legislative branch of state or federal government cannot constitutionally authorize a statewide agency to exercise the basic judicial power reserved to the courts. However, I take issue with Laisne’s conclusion that the determination of questions of fact, as well as questions of law, is an exclusively judicial function. There is substantial authority to the effect that administrative agencies exercise quasi-judicial factfinding functions as a necessary adjunct to the performance of legislatively delegated duties, and that the exercise of these functions does not violate the doctrine of separation of powers. (1 Davis, Administrative Law Treatise, ch. 1, § 1.09; Forkosch, Constitutional Law (2d ed. 1969) ch. IX, §§ 178-180; McGovney, supra, fn. 1, 29 Cal.L. Rev. 110, at pp. 117-129; see Commission v. Havemeyer, 296 U.S. 506, 516-518 [80 L.Ed. 357, 364-365, 56 S.Ct. 360]; Crowell v. Benson, supra, 285 U.S. 22, 50; R. F. C. v. Bankers Trust Co., 318 U.S. 163, 168-171 [87 L.Ed. 680, 686-688, 63 S.Ct. 515].)14 In fact, several cases have indicated that the separation of powers doctrine limits the extent to which administrative determinations, including licensing functions, may be sub*156ject to independent judicial review. (See 4 Davis, Administrative Law Treatise, ch. 29, § 29.10, and cases cited.) It is also noteworthy that in 1966 article III of the California Constitution was revised to eliminate the former reference to judicial “functions.” Only judicial “power” is covered by new article III.

Moreover, it is apparent that practical necessity precludes continued reliance upon a strict separatist theory of government.15 The rapid technological growth and economic expansion which resulted in the creation and proliferation of administrative agencies likewise has placed ever-increasing burdens upon the judiciary. Only the most compelling reasons should lead us to perpetuate the uneconomic duplication of effort inherent in an independent judgment review. Likewise, there is no justification whatsoever for permitting the courts to ignore or overrule the administrative decisions of statewide agencies whose experience and expertise best qualify them, and not the courts, to make those decisions. From the foregoing discussion, it seems clear that the separation of powers doctrine does not afford a firm basis for sustaining the independent judgment rule. Therefore, I would conclude that the provisions of the California Constitution do not forbid the administrative exercise of such quasi-judicial functions as making factual determinations which are binding upon the courts if supported by substantial evidence.

The question remains, however, whether a broader review is required in cases involving “vested” or “constitutional” rights.

The Drummey and Laisne cases, supra, invoked the due process clause of the Fourteenth Amendment of the U.S. Constitution to support the theory that an independent judgment review was required of decisions of statewide administrative agencies which are claimed to deprive a litigant of his “vested” or “constitutional” rights. As stated in Drummey, supra: “[F]or a purely administrative board to deprive a person of an existing valuable privilege without the opportunity of having the finality of such action passed upon by a court of law, would probably violate the due process clause of the federal Constitution. Although there is some confusion in the federal cases, the more recent decisions by the United States Supreme Court have indicated that if binding fact-finding power is conferred on purely administrative boards, and if the courts in reviewing the administrative board’s actions do not exercise an independent judgment on the facts as well as on the law, then the party adversely affected, at least *157where constitutional rights are involved, has been deprived of due process.” (13 Cal.2d at p. 84.)16

The court in Drummey and Laisne, supra, relied primarily upon two rate cases, Ohio Valley Water Co. v. Ben Avon Borough, 253 U.S. 287 [64 L.Ed. 908, 40 S.Ct. 527] (referred to in the treatises and legal publications as the Ben Avon case), and St. Joseph Stock Yards Co. v. United States, 298 U.S. 38 [80 L.Ed. 1033, 56 S.Ct. 720]. The Ben Avon case held that if one attacks a rate as confiscatory, thereby asserting its unconstitutionality as a deprivation of property without due process of law, the complaining party must be given an opportunity to submit that constitutional question to a judicial tribunal for its independent judgment on both the facts and the law.17 However, the St. Joseph case made it clear that the courts should not disregard the administrative record but must presume in favor of the agency’s determination, and that the complainant must make a “convincing showing” that the order involved would result in confiscation. (298 U.S. at p. 53 [80 L.Ed. at p. 1042].)18

The Ben Avon case has been the subject of considerable discussion in legal publications, and the general consensus appears to be that its holding would no longer be followed by the United States Supreme Court. (4 Davis, Administrative Law Treatise, ch. 29, § 29.09, at pp. 167-168; Gellhom and Byse, Administrative Law (4th ed.), at pp. 478-481; Stason, “Substantial Evidence” in Administrative Law, 89 U.Pa.L.Rev. 1026, at pp. 1032-1033; Benjamin, Judicial Review of Administrative Adjudication, 48 Colum.L.Rev. 1, 30; see 2 Cooper, State Administrative Law, ch. XIX, § 2 [1965 ed.] at pp. 673-674; Landis, The Administrative Process, ch. IV; but see Jaffe, Judicial Control of Administrative Action (1965), at pp. 648-652; Jaffe and Nathanson, Administrative Law, ch. 3, § A, at pp. 434-438; Joslin and Miller, Public Utility Rate Making Regulation: A Re-examination, 43 Va.L.Rev. 1027, 1037-1047.)

The foregoing conclusion is substantiated by later Supreme Court decisions in the area of rate regulation and analogous contexts. (See R. R. Commission v. Oil Co., 311 U.S. 570, 575-576 [85 L.Ed. 358, 361-362, 61 S.Ct. 343]; Power Comm’n v. Pipeline Co., 315 U.S. 575, 596 [86 L. Ed. 1037, 61 S.Ct. 736]; Alabama Public Service Comm’n v. Southern Ry. Co., 341 U.S. 341 [95 L.Ed. 1002, 71 S.Ct. 762]; American Trucking *158Assns. v. United States, 344 U.S. 298, 321-323 [97 L.Ed. 337, 361-362, 73 S.Ct. 307]; Consolo v. Federal Maritime Comm’n., 383 U.S. 607, 618-621 [16 L.Ed.2d 131, 139-141, 86 S.Ct. 1018]; see also Preston County Light & P. Co. v. Public Serv. Com’n. of W. Va. (S.D.W.Va. 1969) 297 F.Supp. 759, 766; N.Y., N.H. & H.R. Co., Bondholders’ Committee v. United States (S.D.N.Y. 1968) 289 F.Supp. 418, 427, fn. 5; Cardinale Trucking Company v. United States (D.N.J. 1964) 232 F.Supp. 339, 343-344.)

Moreover, neither the United States Supreme Court nor the lower federal courts has ever applied the so-called “Ben Avon” rule of independent judgment review to license or permit decisions such as those presented in Drummey, Laisne, or the instant case.19 Instead, these courts have upheld administrative findings of fact in such cases if supported by substantial evidence. (Commission v. Havemeyer, supra, 296 U.S. 506, 516-518 [cancellation of franchise]; Federal Communications Commission v. WOKO, Inc., 329 U.S. 223, 226-229 [91 L.Ed. 204, 207-208, 67 S.Ct. 213] [denial of license renewal]; Securities Comm’n v. Chenery Corp., 332 U.S. 194, 207-208 [91 L.Ed. 1995, 2004-2005, 67 S.Ct. 1575] [disapproval of reorganization plan]; Cameron v. Civil Aeronautics Board (7th Cir. 1944) 140 F.2d 482, 483, cert. den. 323 U.S. 716 [89 L.Ed. 576, 65 S.Ct. 43] [license restriction]; Nadiak v. Civil Aeronautics Board (5th Cir. 1962) 305 F.2d 588, 592, cert. den. 372 U.S. 913 [9 L.Ed.2d 722, 83 S.Ct. 729] [revocation of license]; Irish v. Securities & Exchange Commission (9th Cir. 1966) 367 F.2d 637, 638, cert. den. 386 U.S. 911 [17 L.Ed.2d 784, 87 S.Ct. 860] [revocation of license]; Marketlines, Inc. v. Securities and Exchange Commission (2d Cir. 1967) 384 F.2d 264, 267, cert. den. 390 U.S. 947 [19 L.Ed.2d 1136, 88 S.Ct. 1033] [revocation of license].)

The foregoing cases compel the conclusion that the United States Constitution does not require an independent judgment review of all administrative decisions which affect or destroy “vested” or “fundamental” rights and that the broad distinction between “vested” and “nonvested” rights established by the earlier California cases has no sound constitutional basis, and therefore should be rejected unless there are strong practical reasons for retaining it.20

*159I can conceive of no such' reasons. On the contrary, I believe that adoption of a uniform rule of substantial evidence review will have several salutary effects: First, a uniform rule would end the present confusion and uncertainty involved in determining which agencies, and which administrative decisions, are subject to independent judgment review. Second, a uniform rule would eliminate the difficulties inherent in applying the independent judgment test and thereby promote uniformity of decisions. Third, a uniform rule would enhance judicial efficiency and economy by relieving our trial courts of the unnecessary burden of reweighing the administrative record and exercising independent judgment thereon.21 Finally, and most important, a uniform rule would assure that administrative expertise and discretion are accorded due weight and consideration by the courts.

It has been suggested that the independent judgment rule evolved at a time of judicial distrust of, and hostility toward, the administrative process.22 However, with the subsequent adoption of the California Administrative Procedure Act23 and the extensive safeguards governing administrative adjudication by statewide agencies,24 including full provision for qualified hearing officers and procedural due process, the Legislature has substantially reduced the risks of administrative abuse. Administrative boards exercising quasi-judicial powers have become a respected, integral part of our system of government.25

Furthermore, the use of a substantial evidence review would not, of course, render administrative decisions immune from judicial scrutiny. Although confined to a substantial evidence test in reviewing the decisions *160of “local” or “constitutional” agencies, the courts heretofore have managed to correct abuses of discretion by these agencies in a wide variety of situations.26

Similarly, the substantial evidence rule has never precluded this court from correcting abuses of discretion or other injustices upon review of the decisions of the Workmen’s Compensation. Appeals Board, even though those decisions inevitably affect or concern the “fundamental” right of an injured employee to just compensation.

Under Code of Civil Procedure section 1094.5, subdivisions (b) and (c), the courts would retain the power to determine whether an agency “has proceeded without, or in excess of jurisdiction; whether there was a fair trial; and whether there was any prejudicial abuse of discretion.” An abuse of discretion is established if the agency “has not proceeded in the manner required by law, the order or decision is not supported by the findings, or the findings are not supported by . . . substantial evidence in the light of the whole record.”27

I would conclude that the safeguards provided by the Administrative Procedure Act and by section 1094.5 are sufficient to allay any concern that adoption of a uniform substantial evidence review might have undesirable consequences. The courts will retain broad power to prevent arbitrary and capricious administrative action.

Therefore, since their reasoning is unsupported by convincing constitutional or practical considerations, this court should overrule the California cases discussed above, to the extent that they require the trial courts to exercise their own independent judgment, based upon the weight of the evidence, in reviewing the decisions of statewide, legislatively created administrative agencies which are claimed to deprive one of his “vested” or “fundamental” rights.

Coughlin, J.,* concurred.

See, e.g., 3 Davis, Administrative Law Treatise (1958), section 24.03, at pages 412-415; Netterville, Judicial Review: The “Independent Judgment” Anomaly (1956) 44 Cal.L.Rev. 262; McGovney, The California Chaos in Court Review of the Decisions of State Administrative Agencies (1942) 15 So.Cal.L.Rev. 391; McGovney, Administrative Decisions and Court Review Thereof in California (1941) 29 Cal.L. Rev. 110; Turrentine, Restore Certiorari to Review State-Wide Administrative Bodies in California (1941) 29 Cal.L.Rev. 275; see generally 2 Cal.Jur.2d, Administrative *152Law, sections 41-44, sections 219-222; California Administrative Mandamus (Cent. Ed. Bar 1966) sections 5.50-5.75, pages 63-91.

Among other problems, the “independent judgment” test has promoted substantial confusion and uncertainty in the courts. See, e.g., Netterville, supra; Kleps, Certiorarified Mandamus Reviewed: The Courts and California Administrative Decisions— 1949-1959 (1960) 12 Stan.L.Rev. 554.

E.g., Drummey v. State Bd. of Funeral Directors, 13 Cal.2d 75 [87 P.2d 848]; McDonough v. Goodcell, 13 Cal.2d 741 [91 P.2d 1035, 123 A.L.R. 1205]; Laisne v. Cal. St. Bd. of Optometry, 19 Cal.2d 831 [123 P.2d 457]. For a refutation of the doctrine asserted in these cases, see the dissenting opinion of Chief Justice Gibson in Laisne, pages 848-869.

E.g., Walker v. City of San Gabriel, 20 Cal.2d 879 [129 P.2d 349, 142 A.L.R. 1383],

E.g., Covert v. State Board of Equalization, 29 Cal.2d 125 [173 P.2d 545],

Moran v. Board of Medical Examiners, 32 Cal.2d 301 [196 P.2d 20]. As pointed out in Justice Traynor’s dissenting opinion in Moran, at page 317, this rule permits the trial court to ignore the agency’s expertise and discretion with impunity, so long as the court’s decision is supported by substantial evidence. See also Western Air Lines, Inc. v. Schutzbank, 258 Cal.App.2d 218, 249 [66 Cal.Rptr. 293].

Compare Laisne, supra, footnote 2, with Walker, supra, footnote 3, and Covert, supra, footnote 4.

McDonough, supra, footnote 2; So. Cal. Jockey Club v. Cal. etc. Racing Bd., 36 Cal. 2d 167 [223 P.2d 1], In his dissent in the latter case, Justice Tray nor pointed out that there is no sound basis for distinguishing between the revocation of a license and the denial of a license for an existing business.

Merrill v. Department of Motor Vehicles, 71 Cal.2d 907, at page 915 [80 Cal.Rptr. 89, 458 P.2d 33]; see generally Beverly Hills Fed. S. & L. Assn. v. Superior Court, 259 Cal.App.2d 306, 312-318 [66 Cal.Rptr. 183]; Kleps, supra, footnote 1, at pages 565-568.

Compare Thomas v. California Emp. Stab. Com., 39 Cal.2d 501 [247 P.2d 561] (unemployment insurance benefits), with Bertch v. Social Wefare Dept., 45 Cal.2d 524 [289 P.2d 485] (old age benefits).

Kleps, supra, footnote 1, at pages 560-565.

Drummey v. State Bd. of Funeral Directors, supra, 13 Cal.2d 75, at pages 85-86; Dare v. Bd. of Medical Examiners, 21 Cal.2d 790, at page 800 [136 P.2d 304],

The commentators assume that the so-called “presumption” will be ignored by the trial courts, since it is totally inconsistent with the concept of an independent judgment review. See, e.g., Kleps, supra, footnote 1, at page 577; Netterville, supra, footnote 1, at pages 279-280; McGovney, supra, footnote 1, 29 Cal.L.Rev. 110, at pages 129-130.

19 Cal.2d at pages 859-866; see .also Justice Traynor’s dissenting opinion in Dare v. Bd. of Medical Examiners, supra, 21 Cal.2d 790, at pages 811-816. The majority in Laisne suggested that the cases from other jurisdictions, or from the federal courts, could be distinguished, since other state constitutions and the U.S. Constitution (art. III, § 1) empower the legislative branch to create “inferior courts,” thus permitting the establishment of administrative agencies exercising judicial or quasi-judicial functions. On the other hand, the California Constitution (former art. VI, § 1) empowered our Legislature to create inferior local courts; consequently only local administrative agencies could exercise judicial functions in California, absent express constitutional authority. (19 Cal.2d at pp. 846-848.)

This rationale disappeared in 1950, when the reference to “inferior courts” was deleted from article VI, section 1. Moreover, contrary to Laisne’s assumption it is generally agreed that federal administrative agencies do not derive their quasi-judicial functions from congressional authority to establish “inferior courts”; these agencies are not the constitutional courts contemplated under article III, section 1, of the U.S. Constitution, but are, in effect, “legislative courts” created by a proper delegation of the basic legislative power. (Crowell v. Benson, 285 U.S. 22, 50 [76 L.Ed. 598, 612, 52 S.Ct. 285]; Forkosch, Administrative Law (1956 ed.), §§ 42-44; McGovney, supra, footnote 1, 15 So.Cal.L.Rev. 391, 407-409.)

As stated by Professor Davis, “The California Supreme Court is exceptional in having taken seriously the notion that judicial power cannot constitutionally be conferred upon a tribunal other than a court.” (1 Davis, Administrative Law Treatise, supra, § 1.09, at p. 66.)

See 1 Davis, Administrative Law Treatise, supra, section 1.09, at pages 67-68; Forkosch, Administrative Law, supra, section 44, at pages 46-47.

The court’s reasoning on this point was criticized by the dissenting opinion of Chief Justice Gibson (19 Cal.2d 848, at pp. 855-859) and by the commentators (see McGovney, supra, fn. 1, 15 So.Cal.L.Rev. 391, 402-405; McGovney, supra, fn. 1, 29 Cal.L.Rev. 110, 134-136.)

Justice Brandéis dissented on this point, joined by Justices Holmes and Clark; see 253 U.S. at page 292 [64 L.Ed. at page 915],

Justice Brandéis concurred in a separate opinion, joined by Justices Stone and Cardozo; see 298 U.S. at page 73 [80 L.Ed at page 1052].

Indeed, the majority in Laisne, supra, expressly recognized that the Ben Avon and St. Joseph cases appeared to be exceptions to the general rule in the federal courts permitting a substantial evidence review. (19 Cal.2d at p. 846.)

The “Ben Avon” rule may or may not survive in the rate regulation area (compare 4 Davis, Administrative Law Treatise, supra, § 29.09, at pp. 167-168, 172-174, with Jaffe and Nathanson, Administrative Law, supra, pp. 434-438), but that question is not before us in the instant case. In California the Legislature adopted an independent judgment standard in providing for review of decisions of the Public Utilities Com*159mission which are claimed to have violated constitutional rights. (Pub. Util. Code, § 1760.) However, this provision does not require a judicial reweighing of all facts underlying the commission’s decision. (See Pacific Tel. & Tel. Co. v. Public Util. Com., 62 Cal.2d 634, 646-647 [44 Cal.Rptr. 1, 401 P.2d 353], and cases cited.)

The Legislature ultimately could provide for the direct appeal of adminstrative decisions to the Courts of Appeal, thereby vesting the appellate function in courts experienced in performing that function.

As stated in the Drummey case, supra, which originated the independent judgment rule and selected mandamus as the appropriate review procedure: “Normally application for such writs should be filed in the trial courts, whose normal function it is to determine . . . controverted issues of fact.” (13 Cal.2d 75, 86.) If a uniform substantial evidence review were adopted, the Court of Appeal rather than the trial court would be the logical forum to perform the review function. Preliminary review by the trial court would be superfluous and uneconomic in cases requiring no determination of controverted issues of fact.

Netterville, supra, footnote 1, at page 264.

Government Code, section 11370 et seq.

Government Code, section 11500 et seq.

It is indeed anomalous that “local” agencies, whose procedures are not governed by the Administrative Procedure Act, are subject only to a substantial evidence review, even though “vested” rights are involved. See text discussion at footnote 6, ante.

See, e.g., Boreta Enterprises, Inc. v. Department of Alcoholic Beverage Control, 2 Cal.3d 85, 94-95 [84 Cal.Rptr. 113, 465 P.2d 1]; Harris v. Alcoholic Bev. etc. Appeals Bd., 62 Cal.2d 589, 594-595 [43 Cal.Rptr. 633, 400 P.2d 745]; Shepherd v. State Personnel Board, 48 Cal.2d 41, 50-51 [307 P.2d 4]; Stoumen v. Reilly, 37 Cal.2d 713, 716-717 [234 P.2d 969]; English v. City of Long Beach, 35 Cal.2d 155, 158-159 [217 P.2d 22, 18 A.L.R.2d 547].

Under section 1094.5, the trial courts must consider “the whole record” and may not isolate only the evidence which supports the board’s findings and thus disregard relevant evidence in the record. (See LeVesque v. Workmen’s Comp. App.. Bd., 1 Cal.3d 627, 638-639, fn. 22 [83 Cal.Rptr. 208, 463 P.2d 432]; cf. Universal Camera Corp. v. NLRB, 340 U.S. 474 [95 L.Ed. 456, 71 S.Ct. 456]; see generally Netterville, The Substantial Evidence Rule in California Administrative Law, 8 Stan.L.Rev. 563, 575-583; Kleps, supra, footnote 1, at pp. 578-580.)

Assigned by the Chairman of the Judicial Council.