California Supreme Court

The People, Petitioner v. the Superior Court of Yuba County, Respondent; Dustin William Sparks, Real Party in Interest

February 8, 201048 Cal. 4th 1

Summary

The court held that a verdict in one defendant's criminal case has no preclusive effect on the prosecution of a different defendant, even when the verdicts appear inconsistent. It overruled the contrary rule because subsequent authority recognized that inconsistent criminal verdicts are an accepted consequence of the jury system and that applying nonmutual collateral estoppel would create inefficiency and arbitrary results. The court affirmed the Court of Appeal's decision setting aside the order that limited Sparks's potential charges.