Michael W. Rogers, Plaintiff-Below, Appellant v. Matthew Morgan, Defendants-Below, Appellees.

Summary

The Supreme Court of Delaware affirmed summary judgment barring Michael Rogers's federal and state invasion-of-privacy claims under collateral estoppel. It held that the consent issues litigated in the criminal suppression hearing were identical to those raised in the civil action, that the intervening mistrial did not erase the suppression ruling, and that the ruling was sufficiently essential to the resulting no-contest conviction. The Court therefore did not reach the alternative merits argument concerning whether Rogers stated a viable invasion-of-privacy claim.