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possession of a firearm during commission of a felony. On retrial, State sought to retry Robinson on the theory “that he was a co-conspirator and/or party to the armed robbery” with co-defendant Womack – the same theory put forth at the first trial. Robinson objected, arguing that the first jury’s verdict had necessarily determined that he wasn’t a co- conspirator. “‘To conduct an issue-preclusion analysis, courts examine the verdict and trial record to determine the facts that the jury necessarily decided in returning its verdict of acquittal and then determine whether the previously determined facts constituted an essential element of the second offense. The doctrine of collateral estoppel will not bar a retrial unless the record of the prior proceeding affirmatively demonstrates that an issue involved in the second trial was definitely determined in the former trial; the possibility that it may have been does not prevent the relitigation of that issue.’ (Citations and punctuation omitted.) Roesser v. State, 294 Ga. 295, 297, 751 S.E.2d 297 (2013).” Rejecting State’s argument and trial court’s ruling “that the jury could have determined that Robinson did not conspire to commit aggravated assault or murder, but he did conspire to commit armed robbery. This was a conflation of the issue of inconsistent verdicts with issue preclusion and collateral estoppel of the party to a crime theory. As Judge Pryor explained in [ United States v. Ohayon, 483 F.3d 1281, 1286(III)(A)(1) (11 th Cir., 2007)], ‘[t]he problem with this argument is that it presumes that the relevant standard is a subjective one—whether [Robinson’s] jury grounded its verdict on an irrational understanding of [party to a crime.] Ashe [ v. Swenson, 397 U.S. 436, 444, 90 S.Ct. 1189, 25 L.Ed.2d 469 (1970)] requires that we apply an objective standard and ask “whether a rational jury” exposed to the same “pleadings, evidence, charge, and other relevant matter” “could have grounded its verdict upon an issue other than” the one [Robinson] seeks to foreclose from consideration. Because we ask what a rational jury would have done, the possibility that the jury’s verdict rested upon error plays no part in our analysis. A rational jury could not have grounded its verdict on a misunderstanding of [participation in a conspiracy] or on any other mistake. Because collateral estoppel is grounded in the Double Jeopardy Clause of the Fifth Amendment the government is barred from correcting inconsistent verdicts by a single jury, even those based on mistake, compromise, or lenity. The possibility of jury nullification also plays no part in collateral estoppel analysis.’ (Citations and punctuation omitted.) Ohayon, 483 F.3d at 1287–1288(III)(A)(2), citing United States v. Brown, 983 F.2d 201, 203 (11 th Cir., 1993) (‘While the possibility of jury nullification may influence the strategy of trial lawyers, it cannot enter into the analysis of courts making collateral estoppel inquiries.’).” “The only rational conclusion from the first trial is that the jury determined that Robinson was not a party to the crimes, and therefore, the State could not propound these theories against him in the second trial for armed robbery.” Humphrey v. Williams, 295 Ga. 536, 761 S.E.2d 297 (July 11, 2014). Following conviction for child molestation, habeas court properly granted relief based on ineffective assistance in failure to obtain court records which would have impeached similar transaction witness. Habeas court erred, however, in holding that the similar transaction evidence was barred by collateral estoppel; Collateral estoppel didn’t apply because 1) the prior record arose from a civil custody proceeding, not a criminal prosecution, and 2) the record came from another state, not a Georgia court or federal court. 1. Distinguishing Moore v. State, 254 Ga. 674, 333 S.E.2d 605 (1985) (similar transaction evidence from prior Georgia prosecution barred “the prior acquittal was necessarily based on the jury's finding that Moore was not a participant in the earlier armed robbery.”). “[T]here was no prior judgment of acquittal in this case, because criminal charges were never brought against Williams in connection with [similar transaction witness] Jessica's allegations.” 2. “Moreover, Moore relied on the United States Supreme Court's holding in Ashe v. Swenson, 397 U.S. 436, 90 S.Ct. 1189, 25 L.Ed.2d 469 (1970), that the doctrine of collateral estoppel in criminal cases is an aspect of the constitutional protection against double jeopardy. However, in Heath v. Alabama, 474 U.S. 82, 106 S.Ct. 433, 88 L.Ed.2d 387 (1985), that Court held under the ‘dual sovereignty doctrine’ that ‘successive prosecutions by two States for the same conduct’ are not barred by the Double Jeopardy Clause. Id. at 88. See also id. at 92 (‘This Court has plainly and repeatedly stated that two identical offenses are not the ‘same offence’ within the meaning of the Double Jeopardy Clause if they are prosecuted by different sovereigns.’); Jackson v. State, 284 Ga. 826, 828, 672 S.E.2d 640 (2009). Compare OCGA § 16–1–8(c) (statutorily barring state prosecution when the accused was formerly prosecuted in federal court for a crime within the ‘concurrent jurisdiction’ of Georgia ‘if such former prosecution resulted in either a conviction or an acquittal and the subsequent prosecution is for the same conduct’). It follows that even if Williams had actually been charged and acquitted in a Florida criminal prosecution premised on Jessica's 1993 allegations, collateral estoppel would not have required the exclusion of the similar transaction testimony in his Georgia trial.” Overruling Salcedo v. State, 258 Ga. 870, 376 S.E.2d 360 (1989) (applying collateral estoppel to “presenting similar transaction evidence about a prior sexual assault for which the defendant was tried and acquitted in Florida, without consideration of Heath and the dual sovereignty doctrine.”). Also casting doubt on Moore , which “appears to conflict with the United States Supreme Court's subsequent decision in Dowling v. United States, 493 U.S. 342, 110 S.Ct. 668, 107 L.Ed.2d 708 (1990). Dowling holds that a defendant's acquittal in a criminal case does not preclude the government, as a matter of double jeopardy, due process, or common-law collateral estoppel doctrine, from presenting evidence of the alleged prior bad act