Kennecott Corp. v. Union Oil Co‪.‬

Anita Mahon, plaintiff below, appeals from a summary judgment in favor of her erstwhile employer, Safeco Title Insurance Company (SAFECO), in an action for alleged wrongful discharge. SAFECO prevailed on the ground that Mahon was collaterally estopped to raise the issue of wrongful discharge because the issue had been determined adversely to her in a prior unemployment compensation proceeding. During the pendency of this appeal the Legislature enacted Unemployment Insurance Code section 1960 (hereafter section 1960) which says that such administrative adjudications shall not be given collateral estoppel effect. We deem the statute applicable to this appeal and will reverse the judgment.