Collateral estoppel bars a litigant from re-arguing a previously decided issue.  In Sneider v. AB Green Gansevoort, LLC, the collateral estoppel barred a defendant from contesting liability in a civil suit where he pled guilty in a prior criminal proceeding.

There, plaintiff and defendant got into a bar fight where the defendant struck plaintiff causing him to fracture his face.  Defendant was arrested for assault and harassment, and later pled guilty to disorderly conduct.  During the criminal proceeding, defendant admitted that he punched plaintiff in the face with the intent to harm, and without justification.

Plaintiff later sued defendant and the bar under the Dram Shop Act.  Plaintiff’s complaint alleged general negligence claims (as opposed to an intentional assault).  Defendant moved to dismiss arguing that there was nothing in the complaint to counter that defendant simply lost his balance and fell onto the plaintiff causing his injuries.

In denying the motion, the court reasoned that since defendant previously pled guilty to punching the plaintiff without justification, liability was a moot issue.  In addition, collateral estoppel barred defendant form re-arguing his liability.

When handling cases that involve prior criminal proceedings, the outcome of the criminal proceedings can have preclusive effect on the subsequent civil suit.

Thanks to Moya O’Connor for her contribution to this post.