N.Y.S.2d 392, 623 N.E.2d at 522 (recognizing that collateral estoppel principles had hardly been applied in criminal cases); Page, 185 Ill.Dec. 475, 614 N.E.2d at 1167 (collateral estoppel principles more commonly used in civil cases); see also Vestal, Res Judicata/Preclusion at 346 n. 7 (finding it interesting that 1942 Restatement of Judgments completely excluded criminal cases from its scope). The “efficiency concerns that drive the collateral estoppel policy on the civil side are not nearly as important in criminal cases because criminal cases involve a public interest in the accuracy and justice of criminal results that outweighs the economy concerns that undergird the estoppel doctrine.” Rodriguez, 11 S.W.3d at 322, quoting U.S. v. Mollier, 853 F.2d 1169, 1175-77 (5th Cir.1988) (<HOLDING>). These public interest concerns apparently
holding that nonmutual collateral estoppel has no application in criminal cases holding that collateral estoppel applies to  1983 claims recognizing the doctrine of collateral estoppel in agency proceedings holding collateral estoppel elements met considering changed circumstances in the context of an exception to the general rule of collateral estoppel holding that the debtor has the burden of showing that collateral estoppel applies