when finally decided in a previous criminal prosecution, cannot be relitigated so as to avoid the intentional acts exclusion of an insurance policy”); State Farm Fire & Cas. Co. v. Groshek, 161 Mich.App. 703, 411 N.W.2d 480, 484 (1987) (“[A]n insured’s plea of guilty to a crime involving intentional conduct ... dispels any triable factual issue regarding the insured’s intention or expectation to cause injury to the victim.”); State v. Gonzalez, 273 N.J.Super. 239, 641 A.2d 1060, 1061 (1994) (“[Ojne who has been convicted of a crime, whether by way of trial or a plea of guilty, should not be permitted to re-litigate, in another forum, the fact of his guilt.”), aff'd, 142 N.J. 618, 667 A.2d 684 (1995); Merchants Mut. Ins. Co. v. Arzillo, 98 A.D.2d 495, 472 N.Y.S.2d 97 (N.Y.App.Div.1984) (<HOLDING>); Commercial Union Ins. Co. v. Mauldin, 62
holding collateral estoppel elements met considering changed circumstances in the context of an exception to the general rule of collateral estoppel holding that the recent expansion of collateral estoppel warrants applying it even when a litigant has previously entered an alfordtype plea and insisted at sentencing that he was framed holding that collateral estoppel applies to  1983 claims holding that the debtor has the burden of showing that collateral estoppel applies holding that collateral estoppel bars relitigation of previously adjudicated matters