What is the test for determining the findings of the California Department of Justice in a judicial review of an administrative action affecting a fundamental right?

As required in judicial review of administrative action affecting a fundamental vested right (here the revocation of a real estate broker's license), the trial court applied the independent judgment test in determining the applicable facts. (Bixby v. Pierno (1971) 4 Cal.3d 130, 93 Cal.Rptr. 234, 481 P.2d 242.) Because neither the department nor respondent challenge the findings of fact of the trial court, we summarize the facts as recorded in the findings.