Stemler v. Florence

Brief Fact Summary.

Black’s estate filed a wrongful death suit in federal and state court.

Synopsis of Rule of Law.

A claim is not prevented under the doctrine of collateral estoppel if the claim was not an essential issue in a previous judgment.

Facts.

Police officers (officrs) arrested Stemler following a drunken altercation including Stemler, Black, and Kritis. The officers put Black into Kritis’s truck, and Black was killed in a car crash. Black’s estate sued the police officers for wrongful death in state court and federal court. The circuit court granted summary judgment to the defendants and the appellate court reversed. The Kentucky Supreme Court reversed because Black was not in police custody. The district court held that Black’s estate was prevented from relitigating the claim regarding Black being in police custody.

Issue.

Whether a judgment on a claim is prevented under the doctrine of collateral estoppel if the claim was not an essential issue in a previous judgment?

Held.

No. The judgment of the district court is reversed. A further holding that Black was not in police custody is not necessary because the state supreme court decided the question regarding whether Black was in custody.

Discussion.

Issue preclusion does not apply where a claim was not a pertinent part of a previous judgment. Collateral estoppel will bar relitigation of the same issue if: (1) the issue was raised in an earlier proceeding, (2) the issue was actually litigated, (3) the issue was decided, (4) and the issue was necessary for the court to render judgment.