State v. Francisco Pacheco, 2017 R.I. LEXIS 87

Pacheco was stopped after multiple traffic infractions and failed to stop at two stop signs; he refused both a preliminary breath test and a chemical breath test at the police station.
Traffic Tribunal dismissed the preliminary refusal for lack of evidentiary foundation and no testimony on reasonable belief.
In Superior Court, the state sought collateral estoppel to bar the chemical-refusal charge; Pacheco was convicted of marijuana possession and chemical refusal.
This Court, on remand, held that cause was not shown and affirmed the conviction; the majority rejected collateral estoppel as to the chemical-refusal charge.
Dissent would have applied collateral estoppel, arguing the Traffic Tribunal decision vitiated the chemical-refusal charge due to identical threshold issue of reasonable belief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether collateral estoppel bars the chemical-refusal charge	Pacheco contends the Traffic Tribunal ruling determined the reasonable-belief issue, so estoppel prevents re-litigation	State argues issues are not identical and that different statutes and post-arrest evidence prevent estoppel	No collateral estoppel; identity of issues not satisfied

State v. Chase, 588 A.2d 120 (R.I. 1991) (probation-revocation collateral estoppel framework and limits)
State v. Godette, 751 A.2d 742 (R.I. 2000) (abrogates Chase; probation context difference clarified)
State v. Gautier, 871 A.2d 347 (R.I. 2005) (collateral estoppel in criminal context; Chase doctrine largely abrogated)
State v. Rodriguez, 917 A.2d 409 (R.I. 2007) (de novo review for collateral-estoppel questions)
Foster-Glocester Regional School Committee v. Board of Review, 854 A.2d 1008 (R.I. 2004) (apply collateral estoppel without mechanical rigidity; equity concern)
State v. DiStefano, 764 A.2d 1156 (R.I. 2000) (reasonable-belief evidence in DUI context)