Defendant had pleaded guilty to specific criminal charges under the False Claims Act. The United States then sued defendant to recover civil damages under the Contract Settlement Act on the same fact situation. When defendant attempted to contest the verity of facts to which he had pleaded guilty in the earlier criminal action, the United States attempted to have defendant estopped as a matter of res judicata, asking the court for a directed verdict as to the issues decided in the criminal action. Held, directed verdict as to those issues to which the defendant had pleaded guilty would be granted when separated from matters based on new issues and facts. United States v. Bower, (D.C. Tenn. 1951) 95 F. Supp. 19.
Wilber M. Brucker, Jr. S.Ed.,
CIVIL PROCEDURE-JUDGMENTS--PLEA OF GUILTY IN CRIMINAL ACTION AS BASIS FOR COLLATERAL ESTOPPEL IN LATER CIVIL ACTION,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol50/iss4/8