Brief Fact Summary. 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.
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.
The purposes of the doctrine are (1) to promote judicial economy by minimizing repetitive litigation; (2) to prevent inconsistent judgments which undermine the integrity of the judicial system; and (3) to provide repose by preventing a person from being harassed by vexatious litigation.View Full Point of Law