Jose Fidel Guajardo, Appellant v. the State of Texas

Summary

The Court held that the appellant could not obtain appellate review of his collateral estoppel claim because he failed to produce a complete record of the prior suppression hearing, and therefore reversed the Court of Appeals and affirmed the trial court's judgment. The decision rests on the principle that a party seeking to invoke collateral estoppel must supply the record of the earlier proceeding so the reviewing court can determine the factual issue actually decided. The Court declined to address whether collateral estoppel applies beyond the double‑jeopardy context. The opinion includes concurring opinions by Justices Hervey, Meyers, and Johnson, which respectively question the record‑sufficiency analysis, emphasize the effect of dismissal on preclusion, and note that the appellant did not preserve error regarding the seized evidence.