- 31 -
Here, the District Court's judgment was vacated. Accordingly,
following Hudson v. Commissioner, supra at 593, collateral estoppel
does not apply to the District Court's conclusions. Moreover, in
vacating the District Court's judgment, the Court of Appeals cast
doubt in particular on the finding that no settlement was reached.
See Manko v. United States, 87 F.3d at 53.
The Court of Appeals concluded that rule 408 of the Federal
Rules of Evidence does not require exclusion of evidence relating
to a civil settlement in a criminal trial, and that the District
Court abused its discretion in holding that evidence of the
settlement was inadmissible as a matter of law. Id. at 55. The
Court of Appeals did not rule on whether a settlement between
petitioner and respondent existed. To a certain extent, the
District Court's finding on this matter was insulated from review,
owing to the court's reliance on rule 408 of the Federal Rules of
Evidence and the fact that even if such a finding were erroneous,
it might not entitle petitioner to a new trial in the criminal
case. Thus, because the Court of Appeals did not rule on the
District Court's finding that no settlement took place, that
finding by the District Court cannot be used as the basis for
collateral estoppel herein. See Hudson v. Commissioner, supra at
593-594. Consequently, for the aforementioned reasons, we reject
respondent's collateral estoppel argument.
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