Hughes v. People
2013 V.I. Supreme LEXIS 80
Supreme Court of The Virgin Is...2013Background
- Khareem Hughes and codefendants were charged with first‑degree murder, among other offenses, for a shooting on August 2, 2009 on St. Croix that killed Almonzo Williams and wounded others.
- Police pursued Hughes in his aunt’s car; Jalani Williams jumped in; Hughes was arrested after a high‑speed chase and crash.
- Arkiesa Hughes and Lynell Hughes (aunt and Arkiesa’s sister) initially provided statements identifying Joh as shooter; later recanted at trial.
- During trial, both Arkiesa and Lynell testified inconsistently; they admitted signing Detective Matthews’ statements but claimed they could not read them.
- The jury convicted Hughes of voluntary manslaughter and reckless endangerment; the Superior Court later issued an amended judgment; this Court reverses those convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was sufficient evidence Hughes aided and abetted the murder | People argues Hughes knowingly aided/participated in the crime | Hughes contends no proof of participation or specific intent to facilitate | Insufficient evidence; reversal of aiding and abetting conviction |
| Whether there was sufficient evidence of reckless endangerment | People supports recklessness based on the car chase and public shooting context | Hughes argues no firearm possession or firing by him; record lacks grave risk | Insufficient evidence; reversal of reckless endangerment conviction |
Key Cases Cited
- Clarke v. People, 55 V.I. 473 (V.I. 2011) (caution against speculative inferences in aiding and abetting)
- United States v. Garth, 188 F.3d 99 (3d Cir. 1999) (specific intent required for aiding and abetting; knowledge alone is insufficient)
- Brown v. People, 54 V.I. 496 (V.I. 2010) (aiding and abetting requires substantial participation and intent)
- Nanton v. People, 52 V.I. 466 (V.I. 2009) (evidence of defendant's distraction or direct participation supports conviction)
- Navarro v. Gov't of VI, 513 F.2d 11 (3d Cir. 1975) (illustrates elements of aiding and abetting in the VI context)
- Fontaine v. People, 56 V.I. 571 (V.I. 2012) (supports standard for sufficiency review in lesser included offenses)
- People v. Thompson, 57 V.I. 342 (V.I. 2012) (notes on relative strength of evidence for lesser included offenses)