Brown v. People
2010 V.I. Supreme LEXIS 62
Supreme Court of The Virgin Is...2010Background
- Brown appeals his September 9, 2008 judgment committing him to life imprisonment without parole for first‑degree murder and related offenses, seeking a new trial on all counts.
- Facts: Halliday was stabbed during a Foot Locker incident in St. Thomas (Sept. 12, 2005); Brown allegedly aided Jacobs, who stabbed Halliday, after Brown supplied a knife upon Jacobs’ request.
- Jacobs testified Brown initiated the confrontation and both men fought Halliday; Jacobs delivered the fatal stabs while Brown allegedly passed the knife.
- Brown’s case relied on defense witnesses portraying him as peaceful; rebuttal witnesses Barthlett and Bradshaw testified to prior bad acts; Brown unsuccessfully moved to rebut with a surrebuttal.
- Trial court denied post‑trial motions for acquittal or new trial in open court; sentencing followed, but the appellate court reviews the denial and the post‑trial rulings for errors.
- The Virgin Islands Supreme Court reverses, holds that the rebuttal witnesses’ admission violated evidentiary rules, and remands for a new trial on all counts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for Brown as an aider and abettor | Brown contends insufficient evidence of aiding and abetting. | People argues evidence supports aiding and abetting. | Sufficient evidence showed Brown aided and abetted Jacobs. |
| Admission of rebuttal witnesses’ specific-act testimony | Brown argues admission violated 5 V.I.C. §§ 887(a) and (b). | People contend rebuttal was permissible to rebut good‑character evidence. | Trial court erred in admitting rebuttal testimony; error not harmless; new trial ordered. |
Key Cases Cited
- Latalladi v. People, 51 V.I. 137 (V.I. 2009) (standard for sufficiency after conviction; review of credibility issues)
- Martinez, Gov’t of the VI v. Martinez (3d Cir. 1985) (premeditation and killer’s mental process guidance)
- Frorup, 963 F.2d 41 (3d Cir. 1992) (elements of aiding and abetting require knowledge and facilitation)
- Mercado, 610 F.3d 841 (3d Cir. 2010) (defendant’s intent to facilitate required for aiding and abetting)
- Gilbert v. People, 52 V.I. 350 (V.I. 2009) (limits on specific bad‑act evidence; character evidence rules)
- In re Sherman, 49 V.I. 452 (V.I. 2008) (narrow construction of evidentiary exceptions; balance of interests)
- Todmann, People v. Todmann (V.I. 2010) (LEGISLATIVE URE treatment and retroactivity considerations)