People v. Superior Court

48 Cal.4th 1, 224 P.3d 86, 104 Cal.Rptr.3d 764 (2010)

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Nature of the Case

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Facts

Sparks (D) was charged with two felony murders. Before his case came to trial, two other persons were tried for the same murders. One was convicted of voluntary manslaughter, and the other was acquitted. Concerned about possible inconsistent verdicts, and applying the doctrine of nonmutual collateral estoppel the superior court ruled that those verdicts prohibit the prosecution from trying D for a crime greater than voluntary manslaughter. The Court of Appeals set aside this holding. This appeal resulted.