Lehtonen v. Payne, 2012 V.I. Supreme LEXIS 59

Payne, as landlord, sued Lehtonen in a FED action seeking eviction after rent nonpayment.
Lehtonen admitted he vacated the premises but alleged Payne and his mother committed violence against him and his property.
The magistrate dismissed the FED action as moot after Lehtonen left and could not be evicted.
Lehtonen moved to set aside and argued his damages counterclaims should be heard in the FED action.
The magistrate amended the order, granting some relief and preserving counterclaims to be pursued in other fora; the FED action, however, remained focused on possession.
The Superior Court affirmed; Lehtonen timely appealed to the Supreme Court seeking reversal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether FED actions may include counterclaims for damages	Lehtonen argues counterclaims should be heard in FED action.	Payne contends Rule 37 bars counterclaims in FED proceedings.	Counterclaims for damages are inappropriate in FED actions.
Whether perjured testimony could affect the magistrate's decision	Lehtonen contends Payne's testimony was perjured and should affect findings.	Payne's testimony is not reevaluated because the key fact—vacatur—undermines potential relief.	No basis to overturn findings because only undisputed fact was Lehtonen vacating.

Hughes v. Virgin Islands Port Authority, 52 V.I. 458 (V.I. 2009) (affirmed that FED actions are limited and consistent with statutory purpose)
V.I. Port Auth. v. Joseph, 49 V.I. 424 (V.I. 2008) (FED action purpose and limitations on remedies)
Merwin & Co. v. Strong, 7 V.I. 282 (D.V.I. App. Div. 1969) (case discussed FED context; limited relevance to damages in FED)
Barzingus v. Wilheim, 306 F.3d 17 (10th Cir. 2010) (arbitration/summary judgment standard analogy (example format))