State v. Ratliff

We accepted review of this case to determine whether the defendant in the present criminal case may preclude the state from relitigating the issue of whether his stop and arrest were valid when an administrative hearings officer in the Motor Vehicles Division (DMV) had previously held the arrest and stop invalid. We hold that the procedure used in this type of administrative hearing provides an insufficient basis to allow the decision in that proceeding to collaterally estop an issue in a criminal case. We affirm the decision of the lower courts.

On October 18, 1984, defendant was stopped by…