California, United States of America
The following excerpt is from Patterson v. Municipal Court, Santa Clara County, San Jose-Milpitas-Alviso Judicial Dist., 232 Cal.App.2d 289, 42 Cal.Rptr. 769 (Cal. App. 1965):
It should be pointed out that in United States v. Oppenheimer (1916) 242 U.S. 85, 37 S.Ct. 68, 61, L.Ed. 161, relied upon in Yates, the prior judgment being considered by the court was obtained in a criminal proceeding and not in a civil proceeding.
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