Stemler v. Florence

Brief Fact Summary.

Plaintiff brought suit against Defendants in both state and federal court for the wrongful death of Conni Black.

Synopsis of Rule of Law.

An issue is barred by collateral estoppel when the same issue in a prior action was raised and actually litigated, material and relevant to the disposition, and necessary and essential to the resulting judgment.

Facts.

Conni Black was killed in a car crash after police officers placed her a car with a drunk driver. In state court, William Chipman (Plaintiff) brought suit for the wrongful death of Conni Black against the three Florence police officers, two Boone County police officers, the City of Florence, and the Boone County Sherriff (Defendants). Defendants filed a motion for summary judgment. Separately, in federal court, Plaintiff brought suit under 42 U.S.C. § 1983 for the wrongful death of Conni Black against Defendants. The Defendants filed a motion to dismiss.

Issue.

Is the Plaintiff’s claim in federal court barred, under collateral estoppel, because the state court already determined Black was not in custody at the time of her death?

Held.

No, the claim is not barred under collateral estoppel because the same issue was not necessary to the state court’s judgment.

Discussion.

The Court determined that the 42 U.S.C. § 1983 claim was not barred by collateral estoppel because it revolved around the issue of whether or not Black was in custody at the time she was placed in the car. Whether or not Black was in the custody at the time she was placed in the car was not necessary to the judgement of the state court, which turned on the issue of whether or not Black was in custody at the time of her death.