Harris v. Washington

In Harris v. Washington, 404 U.S. 55, 30 L. Ed. 2d 212, 92 S. Ct. 183 (1971), when an ultimate issue has been decided, the constitutional guarantee of collateral estoppel applies "irrespective of whether the jury considered all relevant evidence, and irrespective of the good faith of the State in bringing successive prosecutions." Id. at 56-57 In Harris v. Washington, a jury acquitted the defendant of murder, finding that the defendant had not mailed the bomb which killed the victim and his infant son and seriously injured the victim's wife. Id. at 55. The Supreme Court found that the State could not reprosecute the defendant for killing the infant based upon additional evidence, namely a threatening letter that the defendant had allegedly sent to the victim's family. Id. at 57. In that case, "the ultimate issue of identity" had already been resolved and therefore could not be relitigated despite new evidence. Id. at 56.