Krahn v. Kinney

In Krahn v. Kinney (1989), 43 Ohio St.3d 103, 107, 538 N.E.2d 1058, the Ohio Supreme Court stated: "Collateral estoppel precludes the relitigation of an issue that has been 'actually and necessarily litigated and determined in a prior action.' Whether a conviction resulted from a defense attorney's incompetence is an issue which can be raised and determined in a prior criminal action where a claim of 'ineffective assistance of counsel' has been made. Thus, collateral estoppel can preclude further litigation on the issue."