State of Tennessee v. Joshua Morris

The State appeals the Knox County Criminal Court’s order dismissing the indictment
against 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 of
collateral estoppel, the State was precluded from relitigating the issue of probable cause
that Defendant was driving under the influence in relation to his DUI charge after a circuit
court determined that probable cause was not established in adjudicating Defendant’s
implied consent violation charge. We conclude that the criminal court erred in finding that
the doctrine of collateral estoppel applied and in dismissing the indictment. Accordingly,
we reverse the criminal court’s dismissal of the indictment, reinstate the indictment, and
remand to the criminal court for further proceedings consistent with this opinion.