David P. Hoult v. Jennifer Hoult
United States Court of Appeals for the First Circuit
157 F.3d 29 (1st Cir. 1998)
Jennifer Hoult (defendant) sued her father David (plaintiff) alleging childhood sexual abuse and rape, relying on repressed-memory testimony from an expert and her own testimony about five specific rapes to overcome a statute-of-limitations defense; the jury found for Jennifer, and David's subsequent appeal was dismissed for lack of prosecution. After Jennifer sent letters to professional associations describing the rapes, David sued her for defamation; Jennifer argued collateral estoppel barred relitigating the rape issue since the earlier jury had effectively already decided it, and the district court agreed, dismissing David's suit; David appealed.
Whether a court may find that collateral estoppel bars a party from litigating an issue if the issue was not an explicit part of an earlier final judgment.