Does collateral estoppel apply to a state judgment in a federal civil rights action?

Under collateral estoppel, or issue preclusion, once a court has decided an issue of fact or law necessary to its judgment, that decision may preclude relitigation of the issue in a suit on a different cause of action involving a party to the first case. Allen, 449 U.S. at 94, 101 S.Ct. 411. State law governs the application of collateral estoppel or issue preclusion to a state court judgment in a federal civil rights action. Allen, 449 U.S. at 96, 101 S.Ct. 411 ; Ayers v. City of Richmond, 895 F.2d 1267, 1270 (9th Cir.1990). In California, four criteria govern the application of collateral estoppel to issues raised in a prior criminal proceeding: (1) the

[90 F.Supp.3d 1078]