State of Tennessee v. Joshua Morris

Syllabus

The State appeals the Knox County Criminal Court's order dismissing the indictmentagainst Defendant, Joshua Morris, charging him with driving under the influence (\DUI\).The State contends that the criminal court erred in concluding that under the doctrine ofcollateral estoppel, the State was precluded from relitigating the issue of probable causethat Defendant was driving under the influence in relation to his DUI charge after a circuitcourt determined that probable cause was not established in adjudicating Defendant'simplied consent violation charge. We conclude that the criminal court erred in finding thatthe doctrine of collateral estoppel applied and in dismissing the indictment. Accordingly,we reverse the criminal court's dismissal of the indictment, reinstate the indictment, andremand to the criminal court for further proceedings consistent with this opinion.