ATLANTA - The Georgia Supreme Court on June 17 held that an agency-level ruling on whether Medicaid payments can be suspended while the state investigates Medicaid fraud criminal violations cannot preclude a future criminal prosecution under the doctrine of collateral estoppel. The state high court concluded that the state did not have the opportunity to fully litigate the alleged criminal conduct before the administrative law judge and, therefore, cannot be barred from filing criminal fraud charges once the investigation was complete (Tyrone Cecil Malloy v. The State, No. S13A0188, Ga. Sup.; 2013 Ga. LEXIS 546).