Williams v. City of Jacksonville Police Dept.

Officers Houston and Burkhart (defendants) stopped Williams (plaintiff) at gunpoint and patted him down. Williams sued the officers and the police department (defendant), raising federal civil-rights claims and state-law claims for negligence, false arrest, assault, and failure to train. After removal, the federal court granted summary judgment on the federal claims, concluding there was probable cause for the stop and that the officers' conduct and force were reasonable, but it declined supplemental jurisdiction and dismissed the state claims without prejudice. Williams refiled the state claims in state court; the defendants' summary-judgment motion based on preclusion was denied, and they appealed.

Whether collateral estoppel bars a party from relitigating an issue that was actually raised, adjudicated, and essential to the judgment in a prior action.