## Facts

- Sparks participated in a robbery during which a co-participant was killed.
- Prosecutors charged Sparks with murder under a felony-murder theory based on the killing of the co-felon during the robbery.
- In related litigation involving another robbery participant, that participant had previously been acquitted of murder for the same killing in a separate trial.
- Sparks sought to bar his prosecution by invoking collateral estoppel based on the other participant’s acquittal, relying on People v. Taylor (1974).
- The prosecution sought writ relief after the trial court proceedings raised the Taylor-based collateral estoppel argument, and the California Supreme Court requested briefing on whether Taylor should be overruled.

## Issues

1. Whether the acquittal of one crime participant in a separate trial collaterally estops the prosecution from trying a different participant for the same homicide under a felony-murder theory.
2. Whether People v. Taylor (1974), which applied nonmutual collateral estoppel against the prosecution based on another defendant’s acquittal, should be overruled.

## Decision

- The California Supreme Court overruled People v. Taylor.
- The court held that a prior acquittal of one participant does not collaterally estop the prosecution from trying another participant for the same homicide.
- The court emphasized that inconsistent jury verdicts across separate trials can occur and are tolerated in the criminal justice system.
- The court granted relief to the prosecution, allowing Sparks’s felony-murder prosecution to proceed notwithstanding the earlier acquittal of a different participant.

## Legal Principles

- Collateral estoppel in criminal cases operates as a limited protection tied to the defendant whose prior acquittal necessarily decided an ultimate fact in that defendant’s favor.
- Nonmutual collateral estoppel against the prosecution, based on an acquittal obtained by a different defendant in a separate trial, is generally unavailable.
- Inconsistent outcomes between separate juries do not, by themselves, establish that the later prosecution is barred; differences in evidence, arguments, or jury lenity can explain divergent results.
- Double jeopardy and its collateral-estoppel component are personal protections and do not ordinarily prevent the state from prosecuting a different defendant for the same criminal episode.

## Conclusion

The court permitted Sparks to be prosecuted for felony murder despite another participant’s prior acquittal for the same killing, holding that collateral estoppel does not bar prosecution of a different defendant and overruling Taylor’s contrary rule.


People v. Superior Court (Sparks), 48 Cal. 4th 1, 224 P.3d 86 (Cal. 2010)