The doctrine has existed in parallel in both civil and criminal proceedings for many decades as a way to stop unnecessary relitigation. The requirements of collateral estoppel guard against undue unfairness by assuming that the party to be bound by a previous judgment had a full opportunity to litigate in the first adjudication. Because of procedural protections in criminal trials, as well as the higher standard of proof, a number of jurisdictions have permitted crossovers in subsequent civil trials of defendants previously convicted in criminal trial. An examination of current Maryland law suggests that attempts by the victim of a criminal act to assert collateral estoppel in a subsequent civil trial would prevail. 63 notes and references.