Id. at 798-99. Similarly, in Wright v. People, 690 P.2d 1257, 1262 (Colo. 1984), this court relied on the defendant's stipulation that the probation report could be used to establish a factual basis for his plea when considering whether the defendant understood the nature of the charges against him. The factual basis in both Wilson and Wright stemmed from outside sources stipulated to by the defendant.

"The doctrine of collateral estoppel `means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit.'" Wright v. People, 690 P.2d 1257, 1260 (Colo. 1984) (quoting Ashe v. Swenson, 397 U.S. 436, 443 (1970)). The doctrine was first developed in the context of civil litigation in order to promote judicial economy, conserve private resources, and protect parties from the prospect of vexatious litigation.

Baker v. State , 425 N.E.2d 98, 101 (Ind. 1981) (holding that collateral estoppel did not bar the State from using prior felony convictions in support of an habitual offender charge where defendant had previously been acquitted of an habitual offender charge based on the same prior felony convictions). See also Wright v. People , 690 P.2d 1257, 1261 (Colo. 1984) (holding that in the context of habitual criminality proceedings, collateral estoppel does not apply to trial court rulings excluding evidence of defendant's prior conviction on the basis that the plea hearing was constitutionally inadequate); Hall v. State , 273 Ind. 507, 405 N.E.2d 530, 536-37 (1980) (holding that collateral estoppel does not apply to preclude the State from relying on prior felony convictions, still existing, where trial court, at previous hearing, dismissed an habitual offender count for insufficient evidence of knowing and voluntary guilty pleas). The double jeopardy concerns arising from attempts by the government to relitigate facts underlying a prior acquittal do not apply to the use of a valid and existing conviction for enhanced sentencing.

The fundamental principle of collateral estoppel is that the defendant should be protected from having to relitigate an issue of ultimate fact once that issue has been determined by a valid and final judgment. See Wright v. People, 690 P.2d 1257, 1260 (Colo. 1984). Because the statutes defining second degree burglary and theft each require an element not included in the other, these crimes are considered separate offenses.

Issue preclusion prevents relitigation of a factual or legal matter that was previously litigated and decided. Wright v. People, 690 P.2d 1257 (Colo. 1984). Claim preclusion bars relitigation of claims or issues which were or could have been raised in a prior suit between the same parties or their privies.

Thus, further explanation is unnecessary where the crime is "'readily understandable to a person of ordinary intelligence from a mere reading of the information without further explanation by the court.'" Leonard, 673 P.2d at 39 (quoting Muniz, 667 P.2d at 1383). Offenses that we have considered to be understandable by persons of ordinary intelligence include aggravated robbery, Wright v. People, 690 P.2d 1257 (Colo. 1984); People v. Edwards, 186 Colo. 129, 526 P.2d 144 (1974), and second degree murder, People v. Gorniak, 197 Colo. 289, 593 P.2d 349 (1979).

The offense of aggravated robbery is relatively simple and is readily understandable to persons of ordinary intelligence. See, e.g., Wright v. People, 690 P.2d 1257 (Colo. 1984); People v. Edwards, 186 Colo. 129, 526 P.2d 144 (1974). The information that was read at the providency hearing charged that Trujillo acted "unlawfully and feloniously" in committing the robberies.

In meeting the requirements of Crim. P. 11, we have not required courts to proceed in a formulaic manner, see Wilson v. People, 708 P.2d 792 (Colo. 1985), but have held instead that the explanation necessary depends on the nature and complexity of the crime. Cabral, 698 P.2d 234; Wright v. People, 690 P.2d 1257, 1261 (Colo. 1984). However, the record must show that the defendant understood the critical elements, including the intent requirement, of the crime to which the plea is tendered.

"Where some explanation is given by the court in accepting the plea, its adequacy is dependent upon the nature and complexity of the crime." Wright v. People, 690 P.2d 1257 (Colo. 1984); People v. Muniz, 667 P.2d 1377 (Colo. 1983).

II. Due process requires that a plea of guilty must be voluntarily and understandingly made. Henderson v. Morgan, 426 U.S. 637 (1976); Wright v. People, 690 P.2d 1257 (Colo. 1984); People v. Leonard, 673 P.2d 37 (Colo. 1983).