Sir William Blackstone noted centuries ago that it is "better that ten guilty persons escape than that one innocent suffer." To that end, the system is intentionally tilted in the defendant's favor with such advantages as the requirement of proof beyond a reasonable doubt. But if one of those ten guilty persons has accomplices and they are tried separately, does it follow that they must also escape? Not in California, as of today. The California Supreme Court held in People v. Superior Court (Sparks), S164614:

Real party in interest, Dustin William Sparks (hereafter defendant or Sparks), was charged with two felony murders. Before his case came to trial, two other persons were tried for the same murders. One was convicted of voluntary manslaughter, and the other was acquitted. Concerned about possible inconsistent verdicts, and applying the doctrine of nonmutual collateral estoppel adopted in a criminal case in People v. Taylor (1974) 12 Cal.3d 686 (Taylor), the superior court ruled that those verdicts prohibit the prosecution from trying defendant for a crime greater than voluntary manslaughter.

We conclude that decisions postdating Taylor, supra, 12 Cal.3d 686, including decisions from this court and the United States Supreme Court, have undermined Taylor's reasoning and the authority on which it relied. Occasional inconsistent jury verdicts are inevitable in our criminal justice system. If a verdict regarding one participant in alleged criminal conduct is inconsistent with other verdicts, all of the verdicts may stand. (Standefer v. United States (1980) 447 U.S. 10, 25-26 (Standefer); People v. Palmer (2001) 24 Cal.4th 856, 860 (Palmer).) Accordingly, a verdict regarding one defendant has no effect on the trial of a different defendant. Courts should determine the propriety of a prosecution based on that prosecution's own record, not a different record. Nonmutual collateral estoppel does not apply to verdicts in criminal cases.

This is a unanimous opinion by Justice Chin. Another bad precedent from California criminal jurisprudence's dark ages bites the dust.