State v. Alvey

OPINION OF THE COURT BY

HAYASHI, J.

This case raises the question whether a finding by a prison disciplinary committee that insufficient evidence existed to punish an inmate for a prison infraction collaterally estops the State from litigating the same issue in a subsequent criminal prosecution. We conclude prison disciplinary committee findings do not have collateral estoppel or res judicata effect on subsequent criminal prosecutions and therefore reverse.

In 1981 Michelle Alvey was a prisoner at Oahu Community Correctional Center (OCCC). On November 16, 1981, a prisoner passed heroin and…