Rouse v. People of the Virgin Islands
Case Caption: Rouse v. People of the Virgin IslandsCase Number: SCT-CRIM-2017-0051Date: 01/17/2024Author: Swan, Ive Arlington Citation: 2024 VI 4Summary: Because 14 V.I.C. of title 14 of the Virgin Islands Code is a codification of the common law presumption of sanity, there was no error in the trial below on charges including attempted murder, assault and firearms violations, when the trial court held that the mere filing of a notice of intent to assert an insanity defense, in compliance with the rules of criminal procedure, does not rebut the presumption of sanity. Additionally, because the evidence in the prosecution’s case-in-chief, in light of common sense and everyday experience, logically and rationally allowed for the conclusion that the defendant’s actions were not a result of mental illness, there was no error when a motion for judgment of acquittal was denied at the close of the prosecution’s case-in-chief. Further, a prosecution witness was qualified to offer expert testimony in this matter and validly undermined the opinions of a defense expert, a valid method of discrediting the defense’s evidence of insanity and creating an issue of fact for the jury to decide. The admission of the testimony from the prosecution witness was not an abuse of discretion. While the prosecution made inappropriate statements during the trial, the evidence in this matter was corroborated by multiple witnesses and exhibits and was simply overwhelming. It is concluded beyond a reasonable doubt that the challenged statements, though improper, did not affect the outcome of the trial. Therefore, the denial of the defense motion for mistrial was not an abuse of discretion. Finally, a jury instruction regarding introduction of some evidence of mental illness by the defense accurately stated the law in the Virgin Islands and the trial court’s refusal to give other instructions requested by the defendant was not error, much less an abuse of discretion. Accordingly, the October 6, 2017 judgment and commitment of the Superior Court is affirmed.Attachment:
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