Randeep S. Mann and John Doe #1, John Doe #2, and John Doe #3, Appellants v. Trent P. Pierce and Melissa Pierce…

Summary

The court affirmed partial summary judgment establishing Mann's liability for the Pierces' tort claims based on offensive collateral estoppel arising from his federal criminal convictions. It held that offensive collateral estoppel may apply to criminal convictions other than murder and concluded that the criminal convictions necessarily established the facts underlying the assault and battery claims, despite differences in the formal elements. The court also held that the pending appellate and postconviction proceedings did not prevent the convictions from receiving preclusive effect and that the notice of appeal substantially complied with the applicable rule. Justice Hart, dissenting, would have required the assault and battery elements to have been actually litigated, while Justice Wood dissented only from addressing notice-of-appeal sufficiency sua sponte and Justice Goodson concurred to support addressing that issue.