Supreme Court upholds murder conviction in teenager's death
Starling's body was found in a wooded ravine at Kingsgate Park in Kirkland in March 1999. Her ex-boyfriend, Jason Roy McDaniels, and his friend, Mullin-Coston, were convicted of her murder in separate trials. Each blamed the other for killing Starling.
After her death, investigators unraveled a plot between Starling, her mother, McDaniels and another man to kill her stepfather. The girl's mother, Teresa Lynn Rose, admitted promising to pay McDaniels $10,000 for that killing.
The murder-for-hire plot was never carried out. Rose was sentenced to 5 years in prison for conspiring with the others.
The motive for Starling's murder has never been made clear, but prosecutors theorize McDaniels killed her because she had been talking to friends about the murder conspiracy.
McDaniels was charged with first-degree murder but convicted only of second-degree murder in Starling's death because jurors could not agree that the crime was premeditated. He was sentenced to 42 years in prison.
Mullin-Coston was then tried and convicted of first-degree murder. The jury in his case decided there was enough evidence of premeditation to justify the more serious charge. He was sentenced to 30 years in prison.
In his appeal, Mullin-Coston argued that because the jury in McDaniels' case decided the crime wasn't premeditated, he should not have been convicted of the more serious charge.
This argument was based on the legal doctrine called "collateral estoppel," which says that once a fact has been finally and legally determined, it cannot be re-litigated. The doctrine is used mostly in civil cases. Its criminal equivalent is the constitutional protection against double jeopardy.
The question for the Supreme Court was whether the decision made by McDaniels' jury should have been binding for the jury in Mullin-Coston's case.
The answer, the high court ruled, is no.
Justice Bobbe Bridge's majority opinion noted that Washington state law specifically says someone can be convicted as an accomplice to a crime, even if the main person accused of committing the crime has been acquitted. And, she said, Mullin-Coston was only tried once so he was never in double jeopardy.
"We decline Mullin-Coston's invitation to depart from the plain intent of the legislature, the sound reasoning of the United States Supreme Court, and the weight of the overwhelming majority of other courts that have addressed the issue," Bridge wrote in the unanimous opinion.
"Instead, we hold that issues decided by one defendant's jury are not binding in the later trial of a different defendant."
The case is State of Washington v. Thomas Mullin-Coston, No. 73765-7.