Government of the Virgin Islands v. Mills, 54 V.I. 972

Mills was convicted in the Territorial Court of the Virgin Islands for assault and battery; sentence 30 days served.
Mills pursued a prior appeal but withdrew it in the assault case.
Mills was also charged and convicted in a separate murder case; notice of appeal filed pro se after murder verdict.
The notice of appeal referenced the assault case case number, not the murder judgment.
Clerks and courts treated Mills' appeal as relating to the murder conviction, but the Virgin Islands Appellate Division later dismissed for Rule 4(c) noncompliance.
This appeal challenges whether the flawed notice satisfies the judgment-designation requirement under Rule 4(c) and FRAP 3(c) despite surrounding circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether flawed notice satisfies judgment-designation rule	Mills sought review of murder judgment; surrounding facts show intent	Mills' notice designated wrong judgment/date, prejudicing no one	Notice sufficient; appeal merited consideration on merits

Becker v. Montgomery, 532 U.S. 757 (2001) (perfection not required if intent is clear and no prejudice)
FirsTier Mortg. Co. v. Investors Mortg. Ins. Co., 498 U.S. 269 (1991) (liberal construction of notices; purposes of notice served)
Torres v. Oakland Scavenger Co., 487 U.S. 312 (1988) (purpose of notice; flexibility in designating judgment)
Bankers Trust Co. v. Mallis, 435 U.S. 381 (1978) (notice should notify court of appeals and opposing party)
United States v. Carelock, 459 F.3d 437 (2006) (distinguishes pro se vs. counsel filing; not controlling here)
Marshall v. Lancarte, 632 F.2d 1196 (1980) (affirmative precedent for identifying intended judgment despite errors)
Schneider v. Colegio de Abogados de P.R., 917 F.2d 620 (1990) (caselaw on flexible notice interpretations)