State v. Starbuck, No. 31845-1-III (Wash. Ct. App. published Sept. 8, 2015).
This appeal arises from the well-publicized murder of Ms. Chanin Starbuck. Recently divorced from Clay Starbuck, Ms. Starbuck’s body was found in her house in a sexually humiliating posture.
The State eventually charged Mr. Starbuck with the murder. Mr. Starbuck, the State alleged, was angry about Ms. Starbuck’s dating, as well as the heavy financial obligations he was under to her. The DNA evidence was equivocal: some of the evidence appeared to link Mr. Starbuck to the murder, but there was also unidentified male DNA at the scene. Mr. Starbuck’s defense relied heavily on that unidentified DNA.
The trial court, however, mostly forbade Mr. Starbuck from introducing evidence that Ms. Starbuck had sexual relationships with other men, and that these men may have killed her. Mr. Starbuck, the trial court held, “was unable to sufficiently connect” these other men to the crime, and evidence about Ms. Starbuck’s dating history was unduly prejudicial.
The court of appeals now affirms the trial court’s exclusion of this evidence—an exclusion, it notes, that was not complete, since the defense was allowed to bring up Ms. Starbuck’s relationship with another man during closing. Mr. Starbuck failed to establish a foundation for his “other suspects” evidence. There just wasn’t any concrete evidence linking either of Ms. Starbuck’s lovers to the murder. The conviction is affirmed.