State v. Spanbauer

Victor Spanbauer was convicted of third-degree sexual assault and one count of fornication. He argues that the charges against him should have been dismissed under the doctrine of collateral estoppel because the same allegations were heard and rejected as the basis for parole revocation. We conclude that collateral estoppel does not apply because the legal principles governing parole revocation differ from those governing criminal proceedings. We also reject Spanbauer’s other claims based on insufficiency of the evidence, and we affirm.

The charges against Spanbauer were based on an incident…