What is the burden of collateral estoppel on a criminal defendant?

Apparently, it is the criminal defendant who bears the burden to demonstrate that the doctrine of collateral estoppel is applicable on the facts of any given case. Certainly, it is he who bears "the burden ... to demonstrate that the issue whose relitigation he seeks to foreclose was actually decided in the first proceeding." (Dowling v. United States, supra, 493 U.S. at p. 350, 110 S.Ct. at p. 673; accord, Schiro v. Farley, supra, 510 U.S. at p. ----, 114 S.Ct. at p. 791.)