had a full and fair opportunity to litigate the issue in the earlier proceeding”. Id. (citing People v. Gates, 434 Mich. 146, 452 N.W.2d 627, 630-31 (1990)). Only the “identity of the party” and the “same issue” requirements are at issue in the instant case. The Care House Defendants and the City Defendants are the same party for purposes of collateral estoppel. “[0]ne of the ‘critical factors’ in applying collateral estoppel is the determination of whether the respective litigants were parties or privy to a party to an action in which a valid judgment has been rendered.” Gates, 452 N.W.2d at 630. Here, assuming, arguendo, that the Care House Defendants are state actors, they would necessarily act in privity with the City Defendants, with whom they are alleged to have conspired. Id. (<HOLDING>). Thus, the “identity of the party” requirement
holding that in case where child was removed from mothers care and placed in the custody of the cabarrus county department of social services under north carolina law the reasonable efforts and best interest determinations are conclusions of law because they require the exercise of judgment holding that the grant county prosecutor had a statutory duty to be legal advisor to the county clerk even though she was not embroiled in litigation in which the county was the real party in interest holding that the department of social and rehabilitation services could be held liable for the sexual abuse of the plaintiff by her stepfather holding that the states department of social services and a county prosecutor were in privity and satisfied the identity of the party requirement holding that county and district attorneys are officers within the judicial department