James Wells v. Jeff Coker, 2013 U.S. App. LEXIS 2875

Wells shot a gun into the air on New Year’s Eve 2007; Coker, a Springfield police officer, shot Wells three times at the scene.
Wells pleaded guilty to Reckless Conduct—Count II—alleging that he discharged a firearm and then pointed it at Coker; the plea colloquy was brief and did not specify whether Wells admitted to pointing the gun.
Wells separately sued Coker and the City under 42 U.S.C. § 1983 and Monell, plus state-law claims; defendants moved for summary judgment arguing Wells admitted pointing the gun by pleading guilty.
The district court granted summary judgment on the basis of judicial estoppel, reasoning Wells admitted pointing the gun due to the plea information; the Seventh Circuit reversed, finding issues about alleged admission were unresolved.
The court held that Wells’s guilty plea did not conclusively establish that he pointed the gun, and neither judicial estoppel nor issue preclusion applied; Illinois practice on using prior pleas is unsettled, so Wells should have an opportunity to contest the underlying facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wells is judicially estopped from denying pointing the gun	Wells did not admit pointing the gun in the plea; the plea covered reckless conduct, not a specific admission	The information and plea colloquy alleged and acknowledged Wells pointed the firearm at Coker	Judicial estoppel does not apply; plea did not conclusively establish the pointed-gun fact
Whether issue preclusion bars Wells from contesting pointing the gun	The criminal judgment did not decide whether Wells pointed the gun; the fact was not necessary to the judgment	The plea information included pointing at Coker as part of the charge	Issue preclusion does not apply
Whether Illinois practice supports preclusion of the underlying facts from subsequent civil cases	Illinois law lacks a uniform preclusion approach for prior guilty pleas; the facts under plea may be contested	Illinois practice may give conclusive effect to prior pleas in certain contexts	Illinois law is unsettled; preclusion doctrines do not resolve the issue here; Wells may contest underlying facts
Whether Wells’s prior guilty plea provides conclusive evidence of the underlying facts in a later civil action	Guilty plea is not necessarily conclusive of the facts underlying the plea	Guilty plea can be admitted as evidence; it may be binding or difficult to contradict	Not conclusive; Wells should be allowed to contest the underlying facts

Kale v. Obuchowski, 985 F.2d 360 (7th Cir. 1993) (distinguishing when estoppel applies in plea contexts; not automatic in criminal/advantageous settlements)
Brown v. Green, 738 F.2d 202 (7th Cir. 1984) (guilty plea treated as admission; but context differs where factual issue is whether the act occurred)
Smith v. Sheahan, 959 F. Supp. 841 (N.D. Ill. 1997) (discusses Illinois practice on admissibility of guilty pleas in later actions)