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P1326 Since the Labor Commissioner did not have jurisdiction to adjudicate issues that arose before an employment relationship began, those issues could not have been raised in an administrative proceeding regarding a claim for unpaid wages, so the Commissioner's conclusions cannot have preclusive effect in subsequent litigation based on the claim that the employer fraudulently induced the employee to leave another job to accept a position.
NOBLE v DRAPER (Labor Commissioner Preclusion) 160 CA4 1 [See: LabC 98 etseq; Mycogen v Monsanto 28 C4 888, P/AT 9/02; Johnson v City 24 C4 61, T/AT 9/00]
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