Derrick Sangster v. Thomas Hines, 703 F. App'x 433

Sangster pled nolo contendere to state drug and firearms charges after a suppression hearing and was sentenced to prison.
At the suppression hearing, the state trial judge found the initial entry/search lawful (consent by Sangster’s brother) and that a subsequent full search was authorized by warrant.
The state court’s adverse suppression ruling was necessary to the prosecution’s case because the evidence was important to conviction.
Sangster filed a § 1983 suit in federal court claiming the search violated the Fourth Amendment.
The federal district court dismissed the § 1983 claim on the ground of issue preclusion (collateral estoppel) under Wisconsin law.
Sangster appealed, arguing application of issue preclusion would be fundamentally unfair; the appellate court affirmed without holding oral argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the state-court suppression ruling precludes Sangster’s § 1983 claim	The state-court decision is not fair to preclude federal litigation because of alleged deficiencies (e.g., evidence considered at the hearing)	The suppression ruling was actually and necessarily decided, and applying issue preclusion is fair under Wisconsin law	Affirmed: issue preclusion applies; state judge held a full hearing, made findings, and Sangster had appellate options he did not use
Whether plea of nolo contendere negates preclusive effect of prior findings	(Hinted) Plea meant evidence was not used at trial, so prior findings became unnecessary	No Wisconsin authority shows a plea extinguishes preclusive effect; defendants treat prior findings as binding	Court declined to decide; Sangster did not press this issue on appeal, so court limited review to fairness argument

Haring v. Prosise, 462 U.S. 306 (dealing with similar issue-preclusion questions in the context of a guilty plea)