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Name: People v. Superior Court (Sparks)
Case #: S164614
Court: CA Supreme Court
District CalSup
Opinion Date: 02/08/2010
Summary

Nonmutual collateral estoppel does not apply to verdicts in criminal cases. Four defendants agreed to an ill-conceived plan to steal marijuana plants from a growing operation protected by two armed guards and two pit bulls. There was controverted evidence that at some point, the plan may also have included threatening the armed guards with a pistol, using an exacto knife to sever the 14-foot plants, and using a roll of duct tape to tie up either the guards or plants. The four approached the property in a driving rain at 1:00 a.m., without the exacto knife or duct tape, and decided to abandon whatever their plan had been. At that point, one of the four either said “We’re going to do it anyway” and entered the property to try a solo Rambo-style robbery to take the plants, or said “I’m going in to buy” and went to the front door alone to ask about a purchase. One of the pit bulls was turned loose, and there were struggles and gunshots. Ultimately, the two guards and the pit bull were killed. The first defendant was tried for felony-murder and acquitted. The second defendant, the shooter, was also acquitted of felony-murder but convicted of two counts of voluntary manslaughter as a lesser offense. The third and fourth defendants sought to bar the prosecution from trying them for felony-murder under People v. Taylor (1974) 12 Cal.3d 686, which held that under a common-law doctrine not previously questioned in vicarious liability cases, collateral estoppel could bar trial of a defendant alleged to be liable for a crime only vicariously (i.e., not as either a perpetrator or an aider and abettor with mens rea) if the sole perpetrator of that alleged crime had been previously acquitted. The trial court granted the collateral estoppel motion as to felony-murder only. The Court of Appeal reversed on the ground that Taylor did not apply, and the Supreme Court granted review to reconsider Taylor. On review, the Supreme Court overruled Taylor, holding that under Standefer v. United States (1980) 447 U.S. 10 and opinions that followed it, a defendant cannot invoke collateral estoppel in a criminal case based on the acquittal of a different defendant. While appellant contended that Taylor merely followed long-established legal doctrine in all types of vicarious liability cases, and that neither Standefer nor any opinion following Standefer involved a vicarious liability case, the Court held that Standefer should limit collateral estoppel in all criminal cases because inconsistent verdicts are permitted in the criminal justice system.