Massa, J.
The decisive question presented is whether convictions entered after a guilty plea have the same preclusive effect in subsequent litigation as those entered after jury or court verdicts. Here, the Appellant Zachary Miller pleaded guilty but mentally ill to voluntary manslaughter, then sued his mental health providers in essence for not preventing his crime. The trial court entered summary judgment for the Providers, but the Court of Appeals endorsed Miller’s ambitious request to relitigate his mens rea by relying on authority from a neighboring state, and reversed. We affirm the trial court and hold in a matter of first impression that in Indiana, guilty pleas have the same preclusive effect as trial verdicts, and Miller thus is collaterally estopped from relitigating his legal responsibility—an issue that was necessarily settled by his plea.
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I. Providers are entitled to summary judgment with respect to Miller’s damages that stem, “in whole or in part,” from his criminal act.
To begin, we acknowledge that Miller and Providers assume the “wrongful acts” doctrine embraced by the Indiana Court of Appeals in Rimert v. Mortell, 680 N.E.2d 867 (Ind. Ct. App. 1997), trans. denied, applies. Under that doctrine, “a person cannot maintain an action if, in order to establish his cause of action, he must rely, in whole or in part, on an illegal or immoral act.” Id. at 871–72. This principle is a rational policy expression “that those who knowingly and intentionally engage in serious illegal acts should not be able to impose liability upon others for the consequences of their own behavior.” Id. at 872. Other state jurisdictions have used this rule to bar actions seeking damages because of the injured party’s “knowing and intentional participation in a criminal act.” Id. But even in those jurisdictions, there is subtle nuance in its application. [Footnote omitted.]
The wrongful acts doctrine has never been formally adopted by this Court. Here, the parties all but assume the doctrine exists without first framing whether this Court should adopt it as a matter of Indiana public policy. And so, because neither party briefed this threshold question, we decline to ratify the doctrine today. To be clear about this unique posture: we do not prejudge the merits of the doctrine in future cases. Instead, in this case we only narrowly assume without deciding whether the doctrine applies in Indiana. From that premise, Providers are thus entitled to summary judgment on Miller’s alleged damages that stem, “in whole or in part,” from his criminal conduct. Id. at 871–72. But any alleged damages for which Miller need not rely on his criminal act to state a claim may be otherwise compensable because such actions would fall outside the reach of the doctrine. See Beal v. Blinn, 9 N.E.3d 694, 701 (Ind. Ct. App. 2014) (distinguishing Rimert to find that plaintiff can recover damages from their attorney for malpractice acts unconnected to the criminal act). Here, however, we need not reach the pre-criminal act damages issue because it is waived. See Pierce v. State, 29 N.E.3d 1258, 1267 (Ind. 2015) (“A litigant who fails to support his arguments with appropriate citations to legal authority and record evidence waives those arguments for our review.”).
Today, we evaluate a single controlling issue: whether guilty pleas are afforded the same preclusive effect as trial convictions. We review this novel issue with fresh eyes as a matter of first impression.
II. Miller is estopped from relitigating his legal responsibility under defensive issue preclusion.
In Indiana, a felony conviction may supply a basis for collateral estoppel—barring the litigation of issues and facts necessarily adjudicated in a prior action. Kimberlin v. DeLong, 637 N.E.2d 121, 124–25 (Ind. 1994); Meridian Ins. Co. v. Zepeda, 734 N.E.2d 1126, 1131 (Ind. Ct. App. 2000), trans. denied. A conviction has also been admissible evidence in a civil action, but not “necessarily conclusive proof” of the facts on which the criminal conviction was based. Id. at 124. Today, we hold that entered guilty pleas are subject to the same preclusive reach as trial convictions.
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First, entered plea agreements are final judgments on the merits. See Virsnieks v. Smith, 521 F.3d 707, 714 (7th Cir. 2008) (guilty pleas “are accorded a great measure of finality” because they “are important components of this country’s criminal justice system”) (quoting Blackledge v. Allison, 431 U.S. 63, 71 (1977)). Because guilty plea agreements effectively determine “the rights of the parties in the suit,” Watford v. State, 270 Ind. 262, 265, 384 N.E.2d 1030, 1033 (1979) (internal citation and quotation marks omitted), we assign them the same weight of finality as convictions from trial, provided the plea satisfied the minimum baseline requirement—i.e., it was entered “knowingly, intelligently, and voluntarily.” See Hockett v. Breunig, 526 N.E.2d 995, 999 (Ind. Ct. App. 1988) (convicted criminal was “precluded from asserting a contrary position” in a malpractice action, when the defendant admitted at the guilty plea hearing that the facts were true and that his plea was “knowingly, intelligently, and voluntarily entered”). And here, Miller’s guilty but mentally ill plea, which resulted in the trial court’s sentencing order finding him guilty of voluntary manslaughter, constituted a final judgment on the merits. See Terrell v. State, 180 Ind. App. 634, 636, 390 N.E.2d 208, 209 (Ind. Ct. App. 1979) (“sentencing is final judgment”).
Second, the identity of the issues requirement is sufficiently met because Miller “knowingly, intelligently, and voluntarily” admitted to committing voluntary manslaughter, see Hockett, 526 N.E.2d at 999, which he then sought to contest on his civil appeal. Voluntary manslaughter is defined as a “person who knowingly or intentionally kills another human being . . . while acting under sudden heat[.]” Ind. Code § 35-42-1- 3(a); Carmack v. State, 200 N.E.3d 452, 459 (Ind. 2023) (emphasis added). Here, Miller pleaded guilty but mentally ill2 in his criminal case, but urged on appeal in his civil lawsuit that “[a]n insane person is not held to be responsible for his acts.” Appellant’s Br. at 12. In essence, his medical malpractice claim turns on the theory that he was insane at the time of the killing. But Miller’s mens rea was already established by his guilty but mentally ill plea, so he is attempting to relitigate the same issue “necessarily adjudicated in the prior proceeding[.]” National Wine & Spirits, 976 N.E.2d at 706. We thus find this issue sufficiently identified.
Finally, Miller is the “party to be estopped” and “was a party” to the “prior action.” National Wine & Spirits, 976 N.E.2d at 704. With this final element satisfied, Providers establish the threshold requirements to apply collateral estoppel. What remains in dispute is the application of two relevant considerations: (a) whether Miller enjoyed a full and fair opportunity to litigate his legal responsibility in the context of his guilty but mentally ill plea, and (b) whether imposing collateral estoppel would be otherwise unfair to him. We address each consideration in sequence.
A. Miller had a full and fair opportunity to litigate his legal responsibility, but he instead chose to enter a guilty but mentally ill plea agreement, and thus waived his opportunity to later challenge his mens rea.
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Miller enjoyed a full and fair opportunity to litigate his now-challenged legal responsibility. For starters, he was never denied his constitutional right to a trial by jury, and his criminal case lasted more than three years, where discovery was available to him. After making a rationally calculated assessment of the risks of litigating his responsibility at trial, Miller “knowingly and voluntarily” waived his right to one. These facts are undisputed. He also testified under oath that he fully understood his constitutional rights and that his plea was freely and voluntarily made. He next conceded that he had the requisite mens rea to commit voluntary manslaughter. And so when he entered his plea agreement, Miller admitted that he “knowingly or intentionally” killed his grandfather in violation of Indiana Code Section 35-42-1-3(a). Because Miller entered this plea agreement, he accepted the factual basis of each element of his crime.
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B. Applying collateral estoppel to Miller would not be otherwise unfair because he entered a guilty but mentally ill plea that accepted the factual basis of his mens rea in his voluntary manslaughter conviction.
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Applying collateral estoppel here would not be unfair for two reasons. First, Miller had his day in court; his guilty plea reflects that fact. He made a tactical decision to enter a plea with the rational goal of securing a reduced sentence for his liability. Unlike Reed, Miller was represented by an attorney who guided him through the proceedings, cf. 808 F.3d at 1108, and facilitated a plea for his client. Second, while Miller’s mens rea was not decided by a jury, he still accepted the factual basis of his voluntary manslaughter conviction, which included the “knowingly or intentionally” element. Similar to the plaintiff in Pritchett who was guilty of “knowingly or intentionally” committing prostitution, Miller’s mens rea was “necessarily” decided when the trial court entered his plea. See 756 N.E.2d at 565. Much like Rimert, Miller’s guilty but mentally ill condition does not allow him to duck the wrongful acts doctrine. See 680 N.E.2d at 875–76. And so the policy motivation for this doctrine applies with equal gravitas to entered pleas. Under these facts, “the application of collateral estoppel is not unfair.” Kimberlin, 637 N.E.2d at 125.
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III. Providers satisfactorily carried their summary judgment burden of establishing that Miller’s damages are not compensable.
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Conclusion
For these reasons, we affirm the trial court’s grant of summary judgment to Providers.
Slaughter and Molter, JJ., concur.
Rush, C.J., concurs in part and dissents in part with separate opinion in which Goff, J. joins.
Rush, C.J., concurring in part and dissenting in part.
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I. The wrongful-acts doctrine, as adopted in Rimert, is in tension with principles of comparative fault.
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Contrary to this statutory scheme, the wrongful-acts doctrine effectively extinguishes the possibility that the plaintiff’s conduct and the defendant’s conduct could each contribute to the plaintiff’s alleged damages. That is, the doctrine treats the parties’ acts as mutually exclusive, inherently unable to coexist or jointly impact the plaintiff’s injury. However, as others have similarly observed, such treatment is in tension with comparative fault principles…
So, while I concur with the majority’s application of the wrongful-acts doctrine here, I am open to examining the tension between the doctrine and the principles of comparative fault in a future case…
II. Miller did not waive his argument contesting the entry of summary judgment on his claims for pre-criminal-act damages, and the Providers are not entitled to summary judgment on those claims.
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Goff, J., joins.