Supreme Court of Arkansas
Randeep S. Mann and John Doe #1, John Doe #2, and John Doe #3, Appellants v. Trent P. Pierce and Melissa Pierce…
December 1, 20162016 Ark. LEXIS 356
Summary
The court affirmed partial summary judgment establishing Mann's liability for the Pierces' tort claims based on offensive collateral estoppel arising from Mann's federal criminal convictions. It held that offensive collateral estoppel may apply to criminal convictions other than murder and concluded that the convictions necessarily established the facts underlying the assault and battery claims, despite differences between the criminal and civil elements. The court also held that the notice of appeal substantially complied with the appellate rules because it was timely and caused no prejudice. Justice Goodson concurred in addressing the notice issue, Justice Wood concurred on the merits but dissented from deciding that issue, and Justice Hart dissented from the collateral-estoppel ruling.