AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law for Jails, Prisons and
Detention Facilities
Defenses: Collateral Estoppel
Prisoner was barred,
by collateral estoppel, from relitigating in federal civil rights lawsuit
claims arising from the first of two fires in his cells, based on a prior
state court proceeding rejecting his claim that the state was negligent
in connection with that fire and therefore responsible for the loss of
his property. Under collateral estoppel, since the prisoner had a full
and fair opportunity to litigate the issue once, the decided issue could
not be revisited. No such bar existed as to claims arising from a second
cell fire which he claimed was an "attack" on his life by a correctional
officer, or subsequent alleged retaliatory actions against the prisoner,
since these were not addressed in the prior state court proceeding. Hernandez
v. Goord, 312 F. Supp. 2d 537 (S.D.N.Y. 2004). [N/R]
Illinois prison officials failed to prove
that plaintiff prisoner failed to exhaust his available administrative
remedies on his federal civil rights lawsuit asserting that they violated
his constitutional rights by failing to ship 99 boxes, containing over
2,800 pounds of his property to California after he was transferred there.
Prisoner stated that he did not know, until after his transfer, that the
material would not be shipped, and it was "doubtful" that he
could use Illinois administrative remedies once he was in a California
prison. Prisoner's federal lawsuit was barred, however, by his prior Illinois
state court mandamus action seeking to force the shipment of the boxes,
in which the state court had rejected his claim. Walker v. Page, No. 00-3990,
59 Fed. Appx. 896 (7th Cir. 2003). [N/R]
A prior verdict in favor of the defendants
in the prisoner's state court lawsuit alleging that correctional officers
assaulted him while transporting him to court barred him from pursuing
a federal civil rights lawsuit under 42 U.S.C. Sec. 1983 over the same
incident claiming that the officers' use of force was excessive. Goodson
v. Sedlack, 212 F. Supp. 2d 255 (S.D.N.Y. 2002). [N/R]
281:72 N.Y. prisoner could not pursue his
federal civil rights lawsuit claiming that officers assaulted him and that
his medical records were altered as part of a coverup of the use of excessive
force against him when a state court previously ruled, in his state law
claim over the same incident that no excessive force was used and no "coverup"
existed. D'Andrea v. Hulton, 81 F. Supp. 2d 440 (W.D.N.Y. 1999).