Percifull

In Lockwood v. Superior Court (1984) 160 Cal.App.3d 667 [ 206 Cal.Rptr. 785 ], the First District Court of Appeal held that proceedings on an information charging felony child abuse and endangerment (Pen. Code, § 273a, subd. (1)) were barred under the doctrine of collateral estoppel by a juvenile court’s determination, in dependency proceedings (Welf. & Inst. Code, § 300) arising out of the same facts, that child abuse had not been proved. The Court of Appeal found all of the technical elements of collateral estoppel; it rejected, without extended discussion, the People’s contention that collateral estoppel should not have applied because the purposes of the two proceedings were different.

Six years later, in Lucido v. Superior Court (1990) 51 Cal.3d 335 [ 272 Cal.Rptr. 767 , 795 P.2d 1223 , 2 A.L.R. 5th 995 ], the Supreme Court concluded that a prosecution for indecent exposure was not barred under the collateral estoppel doctrine by a determination, at an earlier probation revocation hearing, that the People had not produced clear and convincing evidence to show that the defendant had committed indecent exposure. The Supreme Court acknowledged that the threshold…