United States v. Francis Brooks, 60 V.I. 904

This is a consolidated appeal by Brooks, Edwards, and John-Baptiste challenging convictions for extortion, kidnapping, bribes, and drug trafficking as Virgin Islands law enforcement officers.
A 53-count superseding indictment was returned in September 2010 and the case proceeded to trial in the District Court.
Evidence at trial included Brooks/Edwards selling marijuana to Moses, extorting for vehicle release, arresting Calixte and detaining her until a ransom was paid, and Lindquist trafficking drugs in exchange for not arresting him.
The District Court granted Rule 29 motions in part, dismissing several counts; Brooks and Edwards were sentenced to 151 months, John-Baptiste to 60 months.
The government cross-appealed the acquittal on certain counts; the panel reverses on counts 5, 6, 10, 11, 12, and 46, and affirms others.
The panel holds that the Virgin Islands false imprisonment/kidnapping statute can be applied to police officers acting without lawful authority, and that evidence supported multiple conspiracy, extortion, and drug-trafficking convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of indictment for double jeopardy	Brooks argues lack of victim names impairs double jeopardy defense.	Brooks contends indictment lacked sufficient factual orientation.	Indictment adequate to preserve double jeopardy; time frame suffices.
Severance for John-Baptiste	John-Baptiste claims severance required to avoid spillover prejudice.	Co-defendants’ evidence prejudices John-Baptiste; severance warranted.	No reversible prejudice; no abuse of discretion in denying severance.
V.I. kidnapping statute's interpretation	John-Baptiste argues the statute is vague and requires ‘without lawful authority’ in practice.	John-Baptiste asserts officers have lawful authority by virtue of peace-officer status.	Statute is not void for vagueness and can apply to unlawful acts by officers.
Rule 29 sufficiency and conspiracy drug count	Evidence insufficient to sustain conspiracy to distribute drugs (count 46) against Brooks/Edwards.	Evidence sufficient under Caraballo-Rodriguez standard; enables reasonable inference of knowledge.	Conspiracy to distribute drugs reinstated; Rule 29 reversal and verdict reinstated.
Prosecutorial misconduct and cross-examination limits	Brooks/Edwards allege withheld exculpatory evidence and improper witness handling.	Government engaged in permissible witness handling; restrictions reasonable.	No reversible prosecutorial misconduct; cross-examination limits within discretion.

United States v. Huet, 665 F.3d 588 (3d Cir. 2012) (indictment need not name victims if it provides time frame and offense elements)
Russell v. United States, 369 U.S. 749 (Supreme Court 1962) (two-part test for indictment sufficiency)
Hamling v. United States, 418 U.S. 87 (Supreme Court 1974) (requirement for sufficient indictment specificity)
Caraballo-Rodriguez, 726 F.3d 418 (3d Cir. 2013) (reaffirmed standard for drug conspiracy knowledge and sufficiency of circumstantial evidence)
Cartwright, 359 F.3d 281 (3d Cir. 2004) (conspiracy proof may be circumstantial; juries may infer agreement)
Gibbs, 190 F.3d 188 (3d Cir. 1999) (evidence of knowledge and intent can be inferred from sustained, long-term association)
Claxton, 685 F.3d 300 (3d Cir. 2012) (evidence of conspiracy can be circumstantial and context matters)
Lambert v. Blackwell, 387 F.3d 210 (3d Cir. 2004) (due process standards for perjury and witness credibility considerations)
Chambers v. Mississippi, 410 U.S. 284 (Supreme Court 1973) (due process limits on exclusion of evidence in trials)