SAN DIEGO - The California labor commissioner is collaterally estopped from assessing penalties against a chain of nail salons that are in direct conflict with a ruling by the California Unemployment Insurance Appeals Board, the Fourth District Court of Appeal ruled July 19 (Happy Nails & Spa of Fashion Valley, L.P., et al. v. Julie A. Su, as Labor Commissioner, et al., No. D060621, Calif. App., 4th Dist., Div. 1; 2013 Cal. App. LEXIS 569).