Safeco Insurance Company America v. David

This appeal involves the question of whether collateral estoppel forecloses consideration in a civil action of an issue previously resolved in a criminal case. We are asked to decide whether the district court properly determined that the appellants were precluded from asserting, in an action to recover damages for wrongful death, that David Yon did not intend to kill Joe Bussell, Jr., after Yon had been convicted of second degree murder for causing the death of Bussell. Appellants, Yon and Bussells heirs,[Footnote 1] maintain that the issue of intent in a civil trial is separate and distinct from the issue of intent in a criminal trial. Bussells heirs also maintain that they were not parties to the criminal trial and consequently the doctrine of collateral estoppel should not apply to them. We affirm the decision of the district court granting summary judgment on the basis of collateral estoppel.