Collateral Estoppel (Issue Preclusion)

Collateral estoppel (issue preclusion) prevents relitigation of specific issues of fact or law that were actually litigated, necessarily decided, and essential to the judgment in a prior proceeding between the same parties.

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Exam Tip

Collateral Estoppel = ISSUE preclusion (not claim). Five elements: identical, actually litigated, necessarily decided, final judgment, fair opportunity. Parklane = limits on offensive use. No mutuality required.

What is Collateral Estoppel?

Collateral estoppel, also called issue preclusion, bars relitigation of specific issues (not entire claims) that were decided in a prior proceeding. Unlike res judicata which bars claims, collateral estoppel bars issues.

Essential Elements

ElementRequirement
Identical IssueSame issue of fact or law
Actually LitigatedIssue was contested and submitted for determination
Necessarily DecidedEssential to the judgment
Valid Final JudgmentPrior judgment was valid and final
Full and Fair OpportunityParty had chance to litigate

Offensive vs. Defensive Use

TypeDefinitionSpecial Rules
DefensiveDefendant uses to prevent plaintiff from relitigating issue plaintiff lostGenerally allowed
OffensivePlaintiff uses against defendant who lost issue beforeSubject to restrictions (Parklane)

California-Specific Rules

  • No mutuality required (Bernhard v. Bank of America)
  • Different burden of proof may preclude issue preclusion
  • Criminal acquittal doesn't preclude civil finding (different standards)

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