State v. Matson

3 Citing cases

  1. Villegas v. State

    No. 59383 (Nev. Sep. 24, 2014)

    But that proposition has this qualification: that both actions are based upon the same facts and both have as their object, 'punishment.' Where the object of the prior civil action and subsequent criminal action is not 'punishment,' res judicata is inapplicable"); People v. Wouk, 739 N.E.2d 64, 70 (Ill. App. Ct. 2000); State v. Matson, No. A09-555, 2010 WL 606775, at *2 (Minn. Ct. App. Feb. 23, 2010); People v. Roselle, 602 N.Y.S.2d 50, 57 (App. Div. 1993), aff'd, 643 N.E.2d 72 (N.Y. 1994).

  2. Criner v. State

    138 So. 3d 557 (Fla. Dist. Ct. App. 2014)   Cited 17 times

    See, e.g., People v. Moreno, 319 Ill.App.3d 445, 253 Ill.Dec. 173, 744 N.E.2d 906, 912 (2001) (“When two proceedings serve different public interests and purposes, those differing concerns may bear upon the State's actions in each proceeding.”); State v. Matson, No. A09–555, 2010 WL 606775 (Minn.Ct.App. Feb. 23, 2010) (holding state not collaterally estopped from prosecuting defendant for criminal sexual conduct against his child, despite TPR ruling that sexual abuse not sufficiently proven); see also State v. Felter, No. H–99–001, 1999 WL 727096 (Ohio Ct.App. Sept. 17, 1999) (reversing dismissal of criminal charges as collateral estoppel was not applicable in criminal action to bar prosecution for criminal offense arising out of same conduct at issue in juvenile case; juvenile court action was not type of civil action in which double jeopardy attaches). The Florida Supreme Court has addressed the preclusive effect that determinations made in probation revocation proceedings—proceedings that are “administrative in nature,” Croteau v. State, 334 So.2d 577, 580 (Fla.1976)—have in subsequent criminal proceedings.

  3. In re Welfare of Child of M.R.G

    No. A10-68 (Minn. Ct. App. Jun. 15, 2010)

    This court affirmed father's conviction of second-degree criminal sexual conduct. State v. Matson, No. A09-555, 2010 WL 606775 (Minn. App. Feb. 23, 2010). This appeal by mother follows.