State v. Mullin-Coston

Thomas Mullin-Coston was convicted of premeditated first degree murder for his participation in the killing of 15-year-old Sarah Starling. In an earlier trial, Mullin-Coston’s friend, Jason McDaniels, was convicted of second degree murder for his own role in Starling’s death. Mullin-Coston argues that his jury inappropriately relied on McDaniels’ premeditation to convict Mullin-Coston based on the law of complicity, even though McDaniels’jury concluded that McDaniels had not acted with premeditation. Mullin-Coston argues that as a result, the doctrine of nonmutual collateral estoppel requires…