Calvin Joseph Reynolds, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals of Texas affirmed the lower court's decision that the Texas Department of Public Safety and the Dallas County District Attorney are not the same parties for collateral estoppel purposes, that the statutory provisions barring administrative findings from precluding criminal litigation are valid, and that the prior administrative license revocation proceeding is not essentially criminal so double‑jeopardy does not apply. The Court declined to vacate or remand the case despite dissenting opinions urging a reconsideration of the parties theory and a determination of whether constitutional collateral estoppel applies.