Frudden Enterprises, Inc. v. Agricultural Labor Relations Board

PANELLI, J.

I respectfully dissent. While I agree that Evidence Code section 1200 is applicable to unfair labor practice proceedings conducted by the Board pursuant to section 1160.2, I cannot agree that Evidence Code section 353 is applicable to this court’s review of a Board decision pursuant to Labor Code section 1160.8. The majority has equated the standard of review afforded by this court to a decision of the Board to that accorded by this court to a decision of a lower court on appeal.

The Board is not a court; it is an administrative agency charged with the administration of this State’s agricultural labor laws (Lab. Code, § 1140 et seq.; Agricultural Labor Relations Bd. v. Superior Court (1976) 16 Cal.3d 392, 399-400 [128 Cal.Rptr. 183, 546 P.2d 687]; Shepard v. N.L.R.B. (1983) 459 U.S. 344, 351 [74 L.Ed.2d 523, 529, 103 S.Ct. 665, 670]). The inapplicability of Evidence Code section 353 to our review of Board decisions under section 1160.8 is illustrated by the statute’s requirement that the reviewing court take the additional step of determining whether the “error or errors complained of resulted in a miscarriage of justice” (Evid. Code, § 353, subd. (b)),1 a procedure not characteristic of our review of an extraordinary writ proceeding. (See Tex-Cal Land Management, Inc. v. Agricultural Labor Relations Bd. (1979) 24 Cal.3d 335, 350-351 [156 Cal.Rptr. 1, 595 P.2d 579]; 5 Witkin, Cal. Procedure (2d ed. 1983 supp.) Extraordinary Writs, § 11 A, pp. 318-319.)

The practical effect of the majority opinion will be the imposition of the strict rules of evidence, which are applicable to trials in courts of record, to hearings before this administrative agency. The result will undoubtedly be to overload the hearing and administrative record with objections and to interfere with the flexibility necessary to have expeditious hearings free from the compulsion of technical rules of evidence.

The majority has also failed to make the distinction between the admissibility of evidence and the sufficiency of evidence to support an administrative finding. (Daniels v. Department of Motor Vehicles (1983) 33 Cal.3d *272532, 538, fn. 3 [189 Cal.Rptr. 512, 658 P.2d 1313].) Mere uncorroborated hearsay does not constitute substantial evidence to support an administrative finding. (Edison Co. v. Labor Board (1938) 305 U.S. 197, 230 [83 L.Ed. 126, 140, 59 S.Ct. 206]; Daniels v. Department of Motor Vehicles, supra, 33 Cal.3d at p. 537.) There must be substantial evidence to support an administrative finding, and hearsay, unless specially permitted by statute, is not competent evidence to that end. (Daniels v. Department of Motor Vehicles, supra, 33 Cal.3d at p. 537; Walker v. City of San Gabriel (1942) 20 Cal.2d 879, 881 [129 P.2d 349, 142 A.L.R. 1383]; Layton v. Merit System Commission (1976) 60 Cal.App.3d 58, 67-68 [131 Cal.Rptr. 318].) It is questionable whether a statute permitting the admission of hearsay, even if it existed, would necessarily sanction sole reliance on uncorroborated hearsay. (Daniels v. Department of Motor Vehicles, supra, 33 Cal.3d at p. 538, fn. 4; see Collins, Hearsay and the Administrative Process: A Review and Reconsideration of the State of the Law of Certain Evidentiary Procedures Applicable in California Administrative Proceedings (1976) 8 Sw.U.L.Rev. 577, 603, fn. 132.)

The uncorroborated hearsay testimony of the Board’s examiner Smith, the sole evidence in support of the finding, does not constitute “substantial evidence” to support the award of travel expenses within the meaning of section 1160.8. I would remand to the Board with directions to set aside the award of travel expenses.

Petitioner’s application for a hearing by the Supreme Court was denied June 14, 1984. Bird, C. J., did not participate therein.

Evidence Code section 353, in its entirety, provides: “A verdict or finding shall not be set aside, nor shall the judgment or decision based thereon by reversed, by reason of the erroneous admission of evidence unless:

“(a) There appears of record an objection to or a motion to exclude or to strike the evidence that was timely made and so stated as to make clear the specific ground of the objection or motion; and
“(b) The court which passes upon the effect of the error or errors is of the opinion that the admitted evidence should have been excluded on the ground stated and that the error or errors complained of resulted in a miscarriage of justice.” (Italics added.)