Carty v. People
56 V.I. 345
Supreme Court of The Virgin Is...2012Background
- Carty was convicted of multiple crimes from two incidents: an assault at Ital Booth and a murder at Jah Yard, tried in a consolidated case.
- Before consolidation, the Ital Booth assault evidence could have been Rule 404(b) evidence in Blyden murder proceedings; consolidation rendered it part of a single case.
- The trial court consolidated the two cases prior to jury selection, creating a nine-count Second Amended Information.
- During deliberations, the jury asked for a written copy of the final instructions, which the court denied.
- The court also admitted Blyden’s sister’s testimony and a graduation photograph, found to be prejudicial but harmless given overwhelming other evidence.
- Carty also challenged the delay in trial as a violation of his Sixth Amendment right to speedy trial, which the court ultimately rejected.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of prior bad acts after consolidation | Carty argues 404(b) error prior to consolidation | People contend consolidation mooted 404(b) issue | Moot post-consolidation; no reversible error |
| Judicial discretion to provide final jury instructions in deliberations | Requests for written instructions were denied; error | Discretionary, no rule requiring written copy | No abuse of discretion; denial affirmed |
| Admission of Blyden sister testimony and graduation photo | Evidence was irrelevant and prejudicial | Evidence unlikely to affect verdict overall | Harmless error; conviction upheld |
| Speedy trial rights violated by pretrial delay | Was incarcerated 25 months before trial; prejudice | Delay attributed to multiple motions and counsels; not prejudicial | No Sixth Amendment violation; convictions affirmed |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (four-factor speedy-trial test governs delay analyses)
- United States v. Starnes, 583 F.3d 196 (3d Cir. 2009) (abuse-of-discretion standard for evidence admissibility)
- Brito v. People, 54 V.I. 433 (V.I. 2010) (standard for appellate review of evidentiary rulings in Virgin Islands)
- United States v. Jones, 353 F.3d 816 (9th Cir. 2003) (jury-instruction-deliberation written-materials discretionary)
- Estate of Ludington v. Jaber, 54 V.I. 678 (V.I. 2011) (plenary review of constitutional questions of law)
- United States v. Diaz, 592 F.3d 467 (3d Cir. 2010) (plenary review of constitutional questions of law)