Kovach v. District of Columbia - 805 A.2d 957 (D.C. Ct. App. 2002)

I. Issue
Whether the earlier proceeding is the essential equivalent of a judicial proceeding when P sued D after paying traffic fines.
II Fact
The District dismissed outstanding fines assessed to some motorists whose infractions were recorded by the H Street bridge camera, but determined that those who had already paid the tickets would not be reimbursed.  P claimed that the District's decision to forgive some fines and enforce others of "similarly situated" motorists who were "unfairly and confusingly" entrapped by the camera was facially discriminatory and violated the Fifth and Fourteenth Amendments of the Constitution.
III. Reasoning
Given P's admission of liability, collateral estoppel precludes appellant from challenging the District's decision as discriminatory as applied to him.  Even where res judicata is inapplicable, collateral estoppel may bar relitigation of the issues determined in a prior action.  Collateral estoppel restricts a party in certain circumstances from relitigating issues or facts actually litigated and necessarily decided in an earlier proceeding.  This principle applies not only to judicial adjudications, but also to determinations made by agencies other than courts, when such agencies are acting in a judicial capacity.
IV. Holding
The earlier proceeding is a judicial proceeding when P sued D after paying traffic fines.