Houston v. City of Coquille

MEMORANDUM *

We affirm on the ground Houston’s claims are barred by collateral estoppel. The validity of Officer Bryant’s stop and subsequent arrest of Houston was actually litigated and necessarily decided in a contested case hearing before the Oregon Department of Motor Vehicles. See Cole v. DMV, 336 Or. 565, 87 P.3d 1120, 1131 (2004). Though a DMV contested case hearing does have not collateral estoppel effect against the state in criminal proceedings, State v. Ratliff, 304 Or. 254, 259-60, 744 P.2d 247, 250 (1987), administrative license revocation proceedings may have such effect in…