Kauffman v. Moss

How later courts describe this case

• posing of hypothetical question, assumed to be equivalent to testimony by a non-testifying co-defendant, created at most only minimal prejudice to defendants
• allowing pro se litigants to amend vague civil rights complaints pursuant to Federal Rule of Civil Procedure 15(a) serves policies of deciding litigation on merits and not denying pro se litigants opportunity to state civil rights claims because of technicalities
• issues essential to guilty verdict must be treated as having been determined by the judgment
• “[reasonable doubt as to what was decided by a prior [criminal] judgment should be resolved against using it as an estoppel [in a later civil action]”
• complaint in a civil rights action is insufficient because it was “broad and conclusory”
• prior criminal judgment is Res judicata only on issues tendered to the jury
• “.. . there can be no collateral estoppel effect as to matters not specifically determined or which were not otherwise essential to the determination of guilt.”
• failure to allege facts showing existence of conspiracy fatal to § 1985 conspiracy claim