Geoghegan v. Retirement Board

In Geoghegan v. Retirement Board (1990) 222 Cal. App. 3d 1525, the Court concluded that the retirement board of the City and County of San Francisco was not collaterally estopped by findings in a prior WCAB proceeding to which the City and County of San Francisco was a party. ( Id. at pp. 1531-1534.) Geoghegan noted that the board was independent from the city and county and only one city and county supervisor was a member of the board. ( Id. at p. 1533.) The board had exclusive jurisdiction over the administration of the retirement system and investment of its funds. (Ibid.) The board operated with complete autonomy, had exclusive control over its trust funds, and operated the retirement system as a contributory, actuarially based system. (Ibid.) Claims for benefits directly impacted members' assessments and fund earnings. (Ibid.) The retirement system's membership included not only employees of the city and county, but also employees of a school district, community college district, a parking authority, and a superior court. (Ibid.) Geoghegan concluded the board was not in privity with the city and county and therefore was not collaterally estopped by the WCAB's findings in the prior proceeding. ( Id. at pp. 1533-1534.)