People v. Sims

Opinion

BIRD, C. J.

This case presents questions that arise when a welfare recipient who has been exonerated of fraud charges in an administrative *473hearing conducted by the Department of Social Services is subsequently prosecuted in a criminal proceeding for the same alleged misconduct. The most significant issue is whether the doctrine of collateral estoppel bars the prosecution from relitigating in the criminal proceeding issues that were previously resolved in the administrative hearing.

I

Respondent, June Sims, is a welfare recipient and mother of three children. By letter dated April 11,…