AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law
for Jails, Prisons and Detention Facilities


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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).


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