Christine Hartman v. Jason Robert Nordmeyer

Summary

The United States District Court for the District of Idaho denied Christine Hartman’s motion for partial summary judgment on her civil assault and battery claims against Jason Robert Nordmeyer. The court held that Nordmeyer’s Idaho criminal convictions for attempted strangulation and battery—domestic violence did not establish collateral estoppel because the criminal offenses did not necessarily decide all identical elements of the civil claims, including imminent fear and lack of consent.

Holdings

1. Nordmeyer's criminal convictions did not collaterally estop him from contesting Hartman's civil assault claim because the criminal offenses did not require proof that Hartman was in imminent fear of harmful or offensive contact, an element of civil assault.
2. Nordmeyer's criminal convictions did not collaterally estop him from contesting Hartman's civil battery claim because the evidence did not establish that lack of consent, an essential element of civil battery, was identical to and actually decided by either criminal conviction.
3. Hartman was not entitled to partial summary judgment on her assault and battery claims.

Questions Presented

1. Whether Nordmeyer's convictions for attempted strangulation and battery—domestic violence collaterally estopped him from contesting liability for Hartman's civil assault claim.
2. Whether Nordmeyer's convictions collaterally estopped him from contesting liability for Hartman's civil battery claim.
3. Whether Hartman was entitled to partial summary judgment under Federal Rule of Civil Procedure 56.

Disposition

other