Citation. 12 Cal. 3d 686,527 P.2d 622, 117 Cal. Rptr. 70,1974 Cal.
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Defendant was in the getaway car when his companions committed a robbery and an individual was killed. Defendant agues that because his companions were acquitted of murder, the State is precluded from litigating the same issue in his case.
Synopsis of Rule of Law.
The doctrine of collateral estoppel can be applied in the limited case where the accused’s guilt must be predicated on his vicarious liability for the acts of a previously acquitted confederate.
Facts.
Defendant was seated in the getaway car when Daniels and Smith, his companions were inside the store committing a robbery. Daniels, Smith, and Defendant were tried separately. Prior to the conclusion of Defendant’s trial, both Daniels and Smith were acquitted of the murder charge. Defendant argues that the doctrine of collateral estoppel should preclude the state from re-litigating the charge of murder in his case.
Issue.
Whether Defendant could successfully assert the doctrine of collateral estoppel once his companions had been acquitted of the crime in their separate trials.
Held.
This holding is limited to the circumstances of this case where an accused’s guilt must be predicated on his vicarious liability for the acts of a previously acquitted confederate.
Collateral estoppel applies if (1) the issue decided at the previous trial is identical to the one sought to be re-litigated; (2) previous trial resulted in a final judgment on the merits; and (3) party against whom collateral estoppel is assessed was a party or in privity with a party at the prior trial.
The purpose of the doctrine is to promote judicial economy, prevent inconsistent judgments, and preventing vexatious litigation.
Discussion.
Because Defendant was in the getaway car at the time of the shooting, Defendant’s murder conviction can only be based on Daniel’s or Smith’s conviction which is vicariously attributed to Defendant. Although the third requirement of the doctrine of collateral estoppel is not met here, the Court ruled that if Defendant’s guilt is based on vicarious liability, then at least one compatriot must be found guilty of the offense. The rest of the discussion focused the applicability of the doctrine of collateral estoppel in the civil arena.
