Williams v. People
59 V.I. 1024
Supreme Court of The Virgin Is...2013Background
- Jalani Williams appeals a May 17, 2012 judgment convicting him of first‑degree murder and related offenses from an August 2, 2009 shooting on St. Croix.
- Two co-defendants were Joh Williams and Khareem Hughes; Williams was chased, apprehended, and found with two .380 firearms and an expended cartridge.
- Aunts Arkiesa Hughes and Lynell Hughes initially identified Joh and Jalani but later recanted at trial.
- During trial, the People sought to admit Arkiesa’s and Lynell’s prior statements under section 19 of title 14; Jalani urged use of those statements only via a witness (Matthews) rather than the written statements themselves.
- Jalani stipulated to use of the statements through Matthews, creating invited error; the court denied admission of the documents but allowed Matthews to recount the statements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of prior inconsistent statements as substantive evidence | Jalani invited section 19 use, seeking admissibility via Matthews | Section 19 should not permit substantive use of the documents; but the court could admit through Matthews | Invited error; review waived; no plain error |
| Discovery obligations and Brady implications | Rule 16(d) violations and Brady material withheld | Disclosures were mostly non‑obligatory or timely; late disclosures were harmless | Rule 16(d) not abused; no Brady suppression; convictions affirmed |
| Invited error doctrine applicability | Jalani consented to use of statements via Matthews | No objection to the approach; error waived | Invited error; no plain error review |
| Remanding for Miller-based juvenile sentencing | Miller v. Alabama requires resentencing for juveniles | Await Miller guidance; violation should be corrected | Remand for resentencing on first‑degree murder with Miller considerations |
Key Cases Cited
- Powell v. People, 59 V.I. 444 (V.I. 2013) (invited error/waiver principles in trial errors)
- Simmonds v. People, 59 V.I. 480 (V.I. 2013) (application of law to admissibility and evidence)
- Latalladi v. People, 51 V.I. 137 (V.I. 2009) (invited error and waiver doctrine)
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life without parole for juveniles unconstitutional; sentencing factors)
- Graham v. Florida, 560 U.S. 56 (U.S. 2010) (juvenile sentencing considerations)
- United States v. Silvestri, 409 F.3d 1311 (11th Cir. 2005) (invited error and appellate consequences)