Beckett v. Department of Social & Health Services

550 P.2d 529, 87 Wash. 2d 184
CourtWashington Supreme Court
DecidedAugust 2, 1976
Docket43917
StatusPublished
Cited by30 cases

This text of 550 P.2d 529 (Beckett v. Department of Social & Health Services) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beckett v. Department of Social & Health Services, 550 P.2d 529, 87 Wash. 2d 184 (Wash. 1976).

Opinions

Hunter, J.

The appellant, Diane Beckett, appeals from [185]*185a King County Superior Court order affirming respondent Department of Social and Health Services’ administrative decision that appellant’s prior acquittal in a criminal proceeding did not bar the respondent from levying a fraudulent overpayment against appellant based on the same factual circumstances.

The facts of this case are not disputed. During the period of January 1971, through April 1972, the appellant received an overpayment of public assistance funds under the Aid for Dependent Children program. Based on these circumstances, she was charged with the fraudulent receipt of public assistance monies and tried for grand larceny. In March 1973, she was acquitted of that charge. Respondent then notified the appellant that it was assessing a fraudulent overpayment against her in the amount of 125 percent of the assistance received during the period in question and that this amount would be collected by deducting 10 percent from her subsequent monthly assistance grants.1 Ap[186]*186pellant requested and received an administrative hearing at which the respondent considered only the question of whether appellant’s prior acquittal in the criminal proceeding barred it from levying a fraudulent overpayment based on the same factual circumstances. The question of whether the appellant had received public assistance as a result of fraudulent misrepresentation was deferred. On May 30, 1973, respondent ruled that it was not barred from proceeding and remanded the case for consideration of the other factual and legal issues. On appeal, the Superior Court rejected appellant’s contentions that the doctrines of collateral estoppel and double jeopardy barred respondent from proceeding, and in its order of July 29, 1974, affirmed respondent’s administrative determination and remanded the matter to respondent for further proceedings. It is from this order that appellant appeals.

Appellant first contends that because of her acquittal in a prior criminal proceeding, the doctrine of collateral estoppel bars the respondent from assessing a fraudulent overpayment based on the same factual • circumstances. Generally speaking, collateral estoppel bars relitigation between the same parties of already determined facts or issues, and among other essential requirements, the doctrine requires a concurrence of identity of cause of action. See Bordeaux v. Ingersoll Rand Co., 71 Wn.2d 392, 395, 429 P.2d 207 (1967). As discussed below, this requirement is not met in the present situation because the two proceedings in question require different burdens of proof.

The standard of proof in civil fraud cases, including the proceedings instituted by respondent in this case pursuant to RCW 74.04.300, is “clear, cogent, and convincing” evidence.' See Hughes v. Stusser, 68 Wn.2d 707, 709, 415 P.2d 89 (1966); Baertschi v. Jordan, 68 Wn.2d 478, 483, 413 P.2d 657 (1966); Williams v. Joslin, 65 Wn.2d 696, 697, 399 P.2d 308 (1965); Bland v. Mentor, 63 Wn.2d 150, 154, 385 [187]*187P.2d 727 (1963). This standard and the “beyond a reasonable doubt” standard applicable to criminal proceedings are not the same and do not connote the same amount of proof. See Bland v. Mentor, supra at 154; Weihl, Our Burden of Burdens, 41 Wash. L. Rev. 109,112-13 (1966).

We are cognizant of our opinion in In re Levias, 83 Wn.2d 253, 256, 517 P.2d 588 (1973). We did there say that the clear, cogent, and convincing test was a “civil counterpart of the criminal reasonable doubt standard,” but this must be read in context with the language following in the opinion wherein we stated that

the clear, cogent, and convincing test applicable in mental illness proceedings exacts the duty that every element essential to proving committable mental illness he demonstrated to a degree essentially corresponding to that necessary for commitment in criminal proceedings. Any lesser standard of proof permits a deprivation of personal liberty through improper suspension of the strict requirements of due process.

(Footnotes omitted. Italics ours.) We then in the footnote specifically preserved the above mentioned distinction in the degree of proof we recognized in Bland between the “beyond a reasonable doubt” standard and the “clear, cogent, and convincing” standard applied in civil fraud cases.

In Standlee v. Smith, 83 Wn.2d 405, 407, 518 P.2d 721 (1974), we recently discussed the application of collateral estoppel in a situation involving differing burdens of proof. There we applied “the rule that a difference in the degree of the burden of proof in the two proceedings precludes application of collateral estoppel” and held that collateral estoppel did not prohibit parole revocation based on the same factual circumstances that had resulted in an acquittal in a prior criminal proceeding.2 See Standlee v. Smith, [188]*188supra at 407, 409. The principles discussed in Standlee are directly applicable to the present case. The burden of proof in appellant’s prior criminal proceeding was different from the burden of proof applicable to the civil fraud proceeding instituted by respondent pursuant to RCW 74.04.300. Therefore, we hold that collateral estoppel does not prohibit the second proceeding.

Appellant’s second contention is that the doctrine of double jeopardy prohibits respondent from assessing a fraudulent overpayment. The purpose of the doctrine is to protect an accused from being twice put in jeopardy for the same offense. See State v. Ridgley, 70 Wn.2d 555, 557, 424 P.2d 632 (1967). Double jeopardy does not apply, however, unless the sanction sought to be imposed in the second proceeding is punitive in nature so that the proceeding is essentially criminal. See Helvering v. Mitchell, 303 U.S. 391, 398, 82 L. Ed. 917, 58 S. Ct. 630 (1938).

The legislature may provide for both civil sanctions and criminal penalties in the same act without thereby converting the civil proceeding to a criminal or penal one. See Helvering v. Mitchell, supra at 399; Yakima County Clean Air Authority v. Glascam Builders, Inc., 85 Wn.2d 255, 260, 534 P.2d 33 (1975); State v. Ralph Williams’ N. W. Chrysler Plymouth, Inc., 82 Wn.2d 265, 278, 510 P.2d 233 (1973).

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Bluebook (online)
550 P.2d 529, 87 Wash. 2d 184, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beckett-v-department-of-social-health-services-wash-1976.