Charles Huddleston and Jessie Huddleston v. M.G.C., Inc., and U.S. Virgin Islands Corporation/M.G.C., Inc. and U.S. Virgin Islands Corporation v. Government of the Virgin Islands

CourtSuperior Court of The Virgin Islands
DecidedJanuary 22, 2024
DocketSX-2022-CV-480
StatusPublished

This text of Charles Huddleston and Jessie Huddleston v. M.G.C., Inc., and U.S. Virgin Islands Corporation/M.G.C., Inc. and U.S. Virgin Islands Corporation v. Government of the Virgin Islands (Charles Huddleston and Jessie Huddleston v. M.G.C., Inc., and U.S. Virgin Islands Corporation/M.G.C., Inc. and U.S. Virgin Islands Corporation v. Government of the Virgin Islands) is published on Counsel Stack Legal Research, covering Superior Court of The Virgin Islands primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Charles Huddleston and Jessie Huddleston v. M.G.C., Inc., and U.S. Virgin Islands Corporation/M.G.C., Inc. and U.S. Virgin Islands Corporation v. Government of the Virgin Islands, (visuper 2024).

Opinion

SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST CROIX CHARLES HUDDLESTON AND JESSIE ' Civil No SX 2022 CV 480 HUDDLESTON

PLAINTIFFS,

V JURY TRIAL DEMANDED M G C , INC , A U S VIRGIN ISLANDS CORPORATION, DEFENDANT CITE AS 2024 VI SUPER 22 M G C , INC , A U S VIRGIN ISLANDS CORPORATION,

THIRD PARTY PLAINTIFF,

V GOVERNMENT OF THE VIRGIN ISLANDS

THIRD PARTY DEFENDANT

Appearances

Douglas L Capdeville, Esq Nathan J Mirocha, Esq Law Office of Douglas L Capdeville, P C MirochaLaw, LLC St Croix U S Virgin Islands St Croix U S Virgin Islands For Defendant/Thzrd Party Plamtzfl For Plamttffls'

Christopher M Timmons, Esq , Esq DEPARTMENT OF JUSTICE St Croix, U S Virgin Islands For Third Party Defendant

MEMORANDUM OPINION AND ORDER

WILLOCKS, Administrative Judge

1] l THIS MATTER came before the Court on Third Party Defendant Government of the

Virgin Islands’ (hereinafter “GVI”) motion to dismiss, filed on April 3, 2023 In response, Third

Party Plaintiff M G C , Inc (hereinafter “MGC ) filed an opposition and GVI filed a reply thereto Huddleston t M G C Inc e! a] SX 2022 CV 480 b Memorandum Opinion and Order 2024 VI SUPER Page 2 of 20

BACKGROUND

1! 2 On October 19 2022 Plaintiff Charles Huddleston and Plaintiff Huddleston (collectively

hereinafter Plaintiffs ’) filed a complaint against MGC, a security company on St Croix, US Virgin Islands, in connection with the Virgin Islands Police Department 3 (hereinafter ‘ VIPD ) response to MGC’s report that an alarm was triggered and a robbery was in progress at Plaintiffs

who were not MGC’s customers residence at 61 Estate Solitude, St Croix, U S Virgin Islands

on October 6, 2022 On December 1, 2022, MGC filed an answer to Plaintiffs’ complaint On

February 8 2023 MGC filed a motion to file a third party complaint against GVI which the Court

subsequently granted In its third party complaint, MGC alleged the following causes of action

against GVI for the actions of VIPD contribution and indemnification ‘ On April 3, 2023, GVI

filed this instant motion to dismiss the third party complaint

DISCUSSION

1] 3 In its motion, GVI argued that the complaint should be dismissed for lack ofsubject matter

jurisdiction and for failure to state a claim upon which relief can be granted pursuant to Rule

12(b)(1) and 12(b)(6) of the Virgin Islands Rules of Civil Procedure

1 Motion to Dismiss for Lack of Subject Matter Jurisdiction

1] 4 In its motion GVI argued that the Court lacked subject matter jurisdiction over MGC’s

claims against GVI because MGC failed to comply with the pre filing requirements of the Virgin

Islands Tort Claims Act (hereinafter ‘ VITCA ), which are jurisdictional to wit GVI argued that

' Here MGC 3 third party complaint did not set forth counts in separate numbered paragraphs with separate designation of the specific names of each count in the pleadings as required by the Virgin Islands Rules of Civil Procedure (hereinafter Rule 8 ) Thus the specific causes of action are deduced from the allegations in MGC 5 third party complaint to wit In the event that Plaintiffs are allowed recovery on their claims from MGC, then MGC is entitled to contribution and/or indemnity from GVI which is or may be liable to MGC for all or part of Plaintiffs damages should they prevail at trial (TPC ) Huddleston t M G C Inc et a] SX 2022 CV 480 Memorandum Opinion and Order 2024 VI SUPER 5 Page 3 of 20

“[the injuries] allegedly occurred on October 6, 2022, ’ which is when the contribution claim

accrued,1 and the 90 day notice period under the VITCA has long expired (Motion )

I! 5 In its opposition, MGC did not dispute that the VITCA is applicable in this instance, but

argued that for the purposes of the 90 day notice period under the VITCA the contribution claim

accrued either from the [date of] entry ofjudgment against the defendant or the date of payment

of more than the defendant’s pro rata share to the plaintiff ’3 (Opp 5 ) Alternatively, MGC argued

that if the Coutt agrees with the accrual date argued by GVI, then ‘ the Court has discretion to grant

MGC leave to file a late notice of intent ”4 (Id )

1] 6 In its reply, GVI reiterated that the contribution claim accrued on the date of the injury 5

(Reply I 3 ) As to MGC s alternate argument, GVI pointed out that MGC ‘ did not file a motion,

no affidavits are before the Court and no reasonable excuse has been given ’ so the Court should

not grant MGC a discretionary extension for the compliance of the pre filing requirements of the

VITCA (Id at 3 4 )

A Standard of Review

1] 7 A motion to dismiss for lack of subject matter jurisdiction pursuant to Rule 12(b)(l) of the

Virgin Islands Rules of Civil Procedure challenges the court’s authority to hear the case V I R

CW P 12(b)(a) The applicable standard of review under Rule 12(b)(1) differs depending on

whether the moving party has made a facial attack or a factual attack on the court's power to hear

the case James St Jules v Thompson 2015 V I LEXIS 74 at *6 (VI Super Ct June 25 2015)

’ For its argument on the accrual date of the contribution claim, GVI did not cite to any authority 3 For its argument on the accrual date of the contribution claim, MGC relied on Dublin v V 1 Tel Corp , 15 V I 214 (VI Terr Ct June9 I978) 4 For its alternative argument, MGC relied on Title 33 V I C § 3409(c) 5 For its argument on the accrual date of the contribution claim, GVI relied on Martinez v Frazer, 23 V I 53 (V I Terr Ct October 23 [987) Huddleston v M G C Inc et a! SX 2022 CV 480 g Memorandum Opinion and Order 2024 VI SUPER Page 4 of 20 When the attack on subject matter jurisdiction is facial, it ‘ is an argument that considers a claim

on its face and asserts that it is insufficient to invoke the subject matter jurisdiction of the court

based on a Jurisdictional defect, ’ and “the court must only consider the allegations ofthe complaint

and documents referenced therein and attached thereto, in the light most favorable to the

plaintiff James St Jules v Thompson 2015 V I LEXIS 74 at *6 7 (V I Super Ct June 25

2015) (internal quotation marks and citations omitted) In other words under a facial attack, the

Court must ‘ apply the same standard of review it would use in considering a motion to dismiss

under Rule 12(b)(6) James St Jules, 2015 V I 74, at *7 On the other hand, when the attack on

subject matterjurisdiction is factual, the defendant disputes the existence of certain jurisdictional

facts alleged by plaintiffs” and the Court ‘ is free to weigh the evidence and satisfy itself as to the

existence of its power to hear the case ’James St Jules, 2015 V 1 74, at *7; see Martinez v

Colombian Emeralds Inc 51 VI 174 189 (VI 2009) (Under Rule 12(b)(1) the court is free

to weigh the evidence and satisfy itself as to the existence of its power to hear the case ”); see also

Daley Jeflers v Graham 69 V I 931 939 n 8 (2018) ( When an attack on subject matter

Jurisdiction is factual the Superior Court is free to evaluate the merits ofjurisdictional claims and

may look beyond the face of the complaint to make this determination ”) In such a case, “no

presumptive truthfulness attaches to plaintiff‘s allegations [and] the burden of proving the

existence of subject matter jurisdiction lies with the plaintiff James St Jules, 2015 V I 74, at *7,

see Franczs v Govtofthe VI No ST 13 CV 387 2014 VI LEXIS 43 at *2 3 (VI Super Ct

July 10 2014) ( Once a defendant challenges a plaintiff‘s pleading on FED R ClV P 12(b)(l)

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Related

Bye v. State
90 Misc. 2d 265 (New York State Court of Claims, 1977)
Martinez v. Colombian Emeralds, Inc.
51 V.I. 174 (Supreme Court of The Virgin Islands, 2009)
In re People
51 V.I. 374 (Supreme Court of The Virgin Islands, 2009)
People v. Simmonds
56 V.I. 84 (Superior Court of The Virgin Islands, 2012)
Simon v. Joseph
59 V.I. 611 (Supreme Court of The Virgin Islands, 2013)
In re Q.G.
60 V.I. 654 (Supreme Court of The Virgin Islands, 2014)
Edney v. Edney
64 V.I. 661 (Supreme Court of The Virgin Islands, 2016)
One St. Peter, LLC v. Board of Land Use Appeals
67 V.I. 920 (Supreme Court of The Virgin Islands, 2017)
Carty v. Beech Aircraft Corp.
679 F.2d 1051 (Third Circuit, 1982)

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