## Facts

- Philip Daniel Taylor lost control of his car on a rural road and collided with an oncoming vehicle; two passengers in Taylor’s car died, and the other driver was injured.
- A grand jury returned multiple indictments, including intoxication manslaughter and manslaughter charges for each passenger’s death, plus assault charges relating to the other driver.
- At Taylor’s request, the trial court severed the cases and tried first the indictment concerning passenger Michelle James.
- In the first trial, lab testing showed alcohol and marijuana in Taylor’s blood, but the State did not oppose a motion in limine excluding marijuana evidence; the prosecution’s intoxication theory was limited to alcohol.
- A toxicology expert testified Taylor’s blood-alcohol level was below the then-legal limit at the time of the crash.
- The jury acquitted Taylor of intoxication manslaughter and reckless manslaughter for James’s death.
- After the acquittal, the State dismissed charges relating to the second passenger (Kyla Blaisdell) but later found a new witness who claimed Taylor had smoked marijuana on the day of the accident.
- The State then sought to prosecute Taylor for intoxication manslaughter for Blaisdell’s death alleging intoxication by marijuana alone or by alcohol and marijuana.

## Issues

1. Whether constitutional collateral estoppel (as part of double jeopardy) precludes the State from relitigating the ultimate issue of intoxication in a later prosecution by alleging a different manner and means of proving intoxication.
2. Whether the first jury’s general acquittal, reached under pleadings, evidence, charge, and argument limited to intoxication by alcohol, necessarily decided that Taylor was not intoxicated at the time of the accident for purposes of a later intoxication manslaughter prosecution arising from the same crash.

## Decision

- The Texas Court of Criminal Appeals affirmed the court of appeals and granted pretrial habeas relief.
- The court held collateral estoppel barred the State from prosecuting Taylor for intoxication manslaughter for Blaisdell’s death on a marijuana (or alcohol-plus-marijuana) theory.
- Based on the first trial’s record, the jury necessarily decided the ultimate fact that Taylor was not intoxicated at the time of the accident.
- The court concluded the intoxicant alleged was a manner and means of proving intoxication, not a separate ultimate fact permitting relitigation.

## Legal Principles

- Collateral estoppel in criminal cases bars relitigation between the same parties of an issue of ultimate fact previously determined by a valid and final judgment.
- To determine what a prior general acquittal necessarily decided, a court must examine the full record of the first case, including pleadings, evidence, the jury charge, counsel’s arguments, and the verdict.
- If the only rational reading of the first verdict is that the jury rejected an elemental fact (here, intoxication at the relevant time), the State may not relitigate that fact in a later prosecution arising from the same conduct, even if the later case involves a different victim and the State offers a different evidentiary theory.

## Conclusion

Because the first trial was pleaded, charged, and argued as an intoxication-by-alcohol case and resulted in a general acquittal, the State was constitutionally estopped from retrying the intoxication element for the same crash by switching to a marijuana-based intoxication theory in a later intoxication manslaughter prosecution.


Ex parte Taylor, 101 S.W.3d 434 (Tex. Crim. App. 2002)