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Prince v. People
2012 V.I. Supreme LEXIS 69
Supreme Court of The Virgin Is...
2012
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Background

  • Prince stabbed his half-brother during an altercation at Ingram’s home; two DV assault charges and two counts of using a dangerous weapon were charged under VI code; trial court gave deadly/dangerous weapon definition and self-defense instruction; defense moved for acquittal arguing failure to disprove self-defense; Prince was convicted on all four counts and sentenced, with counts 3 and 4 merged into 1 and 2; appellate review followed after final judgment in 2010.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Deadly weapon instruction adequacy Prince contends the instruction equated dangerous with deadly weapon and lacked a clear list. The instruction followed common-law standard and properly defined deadly weapon. Instruction proper; no plain error from lack of exhaustive list.
Interchangeability of terms deadly/dangerous Equating terms misled jury and affected verdict. Terminology interchange is common and harmless in context. No reversible error; terms sufficiently synonymous in charge as a whole.
Necessity of additional self-defense defenses Court should have instructed on sections 41, 44, and 293 defenses. Self-defense instruction under §43 encompassed relevant defenses; others not warranted by record. Self-defense instruction sufficient; no error in omitting other defenses.

Key Cases Cited

  • Phipps v. Gov’t of the V.I., 241 F. Supp. 2d 507 (D.V.I. App. Div. 2003) (defines deadly weapon with circumstances of use; supports no need for exhaustive list)
  • Gov’t of the V.I. v. Robinson, 29 F.3d 878 (3d Cir. 1994) (deadly weapon analysis relies on use and intent; common-law standard)
  • Gov’t of the V.I. v. Bedford, 671 F.2d 758 (3d Cir. 1982) (interchangeable use of weapon terms not reversible error when charges align)
  • Fleming v. People, 775 F. Supp. 2d 765 (D.V.I. App. Div. 2011) (courts consider overall charge; not every ambiguity requires reversal)
  • Elizee v. People, 54 V.I. 466 (V.I. 2010) (preserves standard for evaluating unpreserved charging errors)
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Case Details

Case Name: Prince v. People
Court Name: Supreme Court of The Virgin Islands
Date Published: Sep 13, 2012
Citation: 2012 V.I. Supreme LEXIS 69
Docket Number: S. Ct. Criminal No. 2010-0076