Webster v. People, 2014 WL 879562

On May 4, 2011, Patrick Webster forcibly demanded his mother Vernice’s car keys, grabbed and threw her multiple times, disabled phones, took her cell phone, and left with the car; Vernice had bruises and later complained of back pain.
Police arrested Webster the next morning; the People charged him with multiple counts including aggravated assault (under 14 V.I.C. § 298(5) — male on female), disturbing the peace (as domestic violence), and unauthorized use of a vehicle.
After a bench trial, the Superior Court convicted Webster of aggravated assault and battery (under § 298(5)), disturbing the peace, and unauthorized use of a vehicle; some weapon-related counts were dismissed.
Webster appealed, arguing § 298(5) is an unconstitutional sex-based classification (raised for first time on appeal) and that evidence was insufficient for the other convictions.
The Supreme Court of the Virgin Islands reviewed the equal-protection claim for plain error and reviewed sufficiency of the evidence de novo (viewing evidence in the light most favorable to the prosecution).

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Constitutionality of 14 V.I.C. § 298(5) (male-on-female aggravator)	People defend statute as addressing physical differences and protecting women from stronger male attackers	Webster contends the statute creates an unconstitutional sex-based classification violating Equal Protection	§ 298(5) is facially sex-based and fails intermediate scrutiny; statute violates Equal Protection; aggravated-assault conviction reversed (plain error)
2. Standard of review for constitutional challenge raised first on appeal	N/A (People bear burden to justify classification)	Webster asks reversal despite not raising below	Court applies plain-error review and finds error plain, affected substantial rights, and would harm integrity of proceedings; exercises discretion to reverse
3. Sufficiency: Disturbing the peace (14 V.I.C. § 622(1))	People: Webster’s conduct (waking, ransacking, assaulting mother) disturbed her peace	Webster argues due process and charging defects; largely waived	Evidence sufficient; conviction affirmed
4. Sufficiency: Unauthorized use of a vehicle (14 V.I.C. § 1382)	People: Vernice’s consent was coerced by physical assault, so Webster was not entitled to possession	Webster argues Vernice consented and he was entitled as son	Trier of fact credited Vernice’s coerced-consent account; evidence sufficient; conviction affirmed

Lawrence v. Texas, 539 U.S. 558 (invalidation of criminal statute under substantive liberty principles; quoted re: equal protection context)
City of Cleburne v. Cleburne Living Center, 473 U.S. 432 (equal protection principle that similarly situated persons be treated alike)
Heller v. Doe, 509 U.S. 312 (rational-basis review standard for most classifications)
Orr v. Orr, 440 U.S. 268 (sex-based classifications trigger heightened scrutiny)
United States v. Virginia, 518 U.S. 515 (intermediate scrutiny standard for sex-based classifications)
Mississippi Univ. for Women v. Hogan, 458 U.S. 718 (sex-stereotype rejection under intermediate scrutiny)
United States v. Knowles, 29 F.3d 947 (conviction under unconstitutional statute is plain error)