- 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.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011