STATE OF FLORIDA, APPELLANT,
v.
PAUL JAMES MURPHY, APPELLEE
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The State appealed the trial court's dismissal of a robbery charge against Murphy in Pasco County. The trial court erroneously applied res judicata based on a prior Pinellas County robbery charge dismissal, reasoning that the Pinellas County judge had heard evidence of the Pasco County robbery before dismissing the Pinellas charge. The appellate court reversed, holding that res judicata does not apply to separate causes of action and that collateral estoppel cannot bind the court on issues not actually adjudicated.
The trial court erred in applying res judicata because the Pasco County and Pinellas County cases involve separate causes of action based on different facts. Collateral estoppel is also inapplicable because the Pinellas County judge's decision did not adjudicate the issue of whether a prima facie case existed for the Pasco County robbery; the judge may have dismissed on other grounds despite hearing the Williams Rule evidence.
[1] Res judicata bars a prosecution only if the state has previously suffered an adverse judgment in a prosecution of the same defendant based upon the same cause of action.
[2] Collateral estoppel can apply to different causes of action, but only binds parties as to issues actually adjudicated in a prior proceeding.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The doctrine of res judicata will bar a prosecution only if the state has previously suffered an adverse judgment in a prosecution of the same defendant based upon the same cause of action.”
Establishes the strict requirement for res judicata that both prosecutions must be based on the same cause of action.
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Join FLexlaw to unlock all legal intelligenceMurphy was charged with robbery in Pasco County along with two other defendants. Prior to the Pasco County prosecution, Murphy faced a separate robber…
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GRIMES, Chief Judge.
By this appeal, the state challenges the trial court’s order granting defendant Murphy’s motion to dismiss.
The state filed an information charging Murphy and two other defendants with a robbery in Pasco County. Murphy thereafter filed a motion to dismiss the information in which he alleged that the undisputed facts in the case did not establish a prima facie case of guilt against him. After a hearing, the court entered an order in which it dismissed the information. The court found that all of the evidence concerning the Pasco County robbery had been presented as Williams Rule evidence1 at a hearing on a motion to dismiss a charge against Mr. Murphy for a robbery in Pinel-las County. The court further found that because the Pinellas County judge had dismissed the Pinellas County charge after hearing the Pasco County evidence, it was bound by the Pinellas County judge’s decision under principles of res judicata.
The court erred in ruling that the Pinellas County judge’s decision was res judicata. The doctrine of res judicata will bar a prosecution only if the state has previously suffered an adverse judgment in a prosecution of the same defendant based upon the same cause of action.2 State v. Gunn, 381 So. 2d 1186 (Fla.2d DCA 1980). The Pasco County case was a separate cause of action based upon different facts.
Appellee’s suggestion, made at oral argument, that the court below was really applying the broader doctrine of collateral estoppel is of no avail. While collateral estoppel can apply to different causes of action, it only serves to bind the parties in the second suit as to issues which were actually adjudicated in the first one. Ashe v. Swenson, 397 U.S. 436, 90 S.Ct. 1189, 25 L.Ed.2d 469 (1970). Here, it cannot be said that this occurred. The court only received a stipulation that the Pinellas County judge had heard the evidence of the Pasco County robbery prior to having dismissed the Pinel-las County information. Williams Rule evidence of the Pasco County robbery, standing alone, could not possibly have convicted the defendant of the Pinellas County robbery.
Thus, the court below could not rule as a matter of law that the Pinellas County judge had found that there was not a prima facie case against the defendant for the Pasco County robbery. The Pinellas County judge may have found that despite the presence of the Williams Rule evidence concerning the Pasco County robbery there simply was not enough other evidence to make out a prima facie case against the defendant on the Pinellas County robbery.
We reverse the order granting the motion to dismiss and remand the case for further proceedings consistent with this opinion.
SCHEB and CAMPBELL, JJ., concur. . Williams Rule evidence is evidence of other crimes which is admissible when relevant to prove a material fact in issue, such as proof of motive, intent, preparation, plan, knowledge or identity. See Williams v. State, 110 So. 2d 654 (Fla. 1959).
. See Busbee v. State, 183 So. 2d 27 (Fla. 1st DCA 1966), in which the court noted, however, that res judicata could be applicable to some situations in which the second prosecution was not for the identical offense as the first.
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Citator
Cited By
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State v. Cahill, 388 So. 2d 354 (Fla. 2d DCA 1980)…note that, in some circumstances, the State may be collaterally estopped from reargu-ing ultimate facts because of the Fifth Amendment bar on double jeopardy. See Ashe v. Swenson, 397 U.S. 436, 90 S.Ct. 1189, 25 L.Ed.2d 469 (1970); Murphy v. State, 382 So. 2d 1380 (Fla.2d DCA 1980). We need not reach the question of whether the action below requires application of collateral estoppel since the initial order no longer stands. The order entered in Case No. 79-1652 is reversed and the case remanded for further p…
Authorities Cited
- Ashe v. Swenson, 397 U.S. 436 (U.S. 1970)
- Williams v. State, 110 So. 2d 654 (Fla. 1959)
- Busbee v. State, 183 So. 2d 27 (Fla. 1st DCA 1966)
- State v. Gunn, 381 So. 2d 1186 (Fla. 2d DCA 1980)