Supreme Judicial Court (October 12, 2007)
Collateral Estoppel: A guilty plea, once accepted, is a final judgment of conviction, and it is sufficient to have collateral estoppel effect in a subsequent case.
Duplicative Convictions: A defendant may properly be punished for two crimes arising from the same course of conduct provided that each crime requires proof of an element that the other does not.
In July 1998, the defendant was a member of a theft ring that broke into an electronics store to steal merchandise. The police found some of the stolen electronics during a traffic stop of the defendant's car. After a failed motion to suppress the evidence, the defendant pleaded guilty to receiving stolen property. In 2002, the defendant was indicted for the 1998 break-in. Again the defendant's motion to suppress the merchandise was denied, and he was convicted of breaking and entering with the intent to commit a felony.
In appealing the breaking and entering conviction, the defendant argued that 1) the court improperly applied collateral estoppel in denying the motion to suppress, and 2) the conviction is duplicative and violates double jeopardy.
Collateral estoppel ensures that when an issue of fact has been determined by a final judgment, that issue cannot again be litigated between the same parties. A guilty plea that has been accepted by the court constitutes a final judgment.
The two separate convictions here are not duplicative under the "same elements" test, as the offenses have no elements in common. Moreover, the defendant's actions were separated in time and by different conduct and intent.