Calvin Joseph Reynolds, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals of Texas affirmed the Court of Appeals’ decision rejecting Reynolds’ claim that the Harris County District Attorney was collaterally estopped from relitigating the issue of reasonable suspicion after an adverse administrative ruling. The majority held that the Texas Department of Public Safety and the district attorney are not the same parties for collateral estoppel purposes, that State v. Brabson controls the parties analysis, and that the statutory provisions expressly preclude collateral estoppel without violating federal double jeopardy principles. Two dissenting opinions argue that the majority should remand for a determination of constitutional collateral estoppel and criticize the parties theory.