In George v. California Unemployment Ins. Appeals Board (2009) 179 Cal.App.4th 1475, the court also recognized that collateral estoppel may apply when an employee files a civil action after challenging disciplinary actions in an administrative proceeding. In George, the employer took disciplinary action against a civil service employee and she challenged the action in administrative proceedings. She did not raise any FEHA statutory claims in those proceedings. The superior court denied her petition for a writ, which challenged the administrative decision, and she filed a civil action alleging the disciplinary actions were intended to retaliate against her for filing a Department of Fair Employment and Housing (DFEH) complaint. The defendant moved for summary judgment on the ground her action was barred by res judicata. The court noted there was no requirement that the employee raise her FEHA claims in the administrative review process, and res judicata did not bar the plaintiff from raising them in a later court action, after challenging the disciplinary action in the administrative proceedings. (Id. at p. 1484.) Collateral estoppel, however, may preclude a later retaliation claim, if the issues decided in the administrative proceedings eliminate an essential element of the employee's claim. (Id. at pp. 1479, 1486.) The administrative decision had upheld some of the disciplinary actions taken against the plaintiff, but had found that other actions were not justified; although the administrative decision was final and binding on the plaintiff, it was not the equivalent of a finding that all of the discipline imposed was just, proper, and nonretaliatory. (Id. at pp. 1487-1488.) Consequently, it did not dispose of the plaintiff's retaliation claim in its entirety, and summary judgment was properly denied. (Id. at p. 1488.)