Government of the Virgin Islands v. Frett

684 F. Supp. 1324, 23 V.I. 433, 1988 WL 52271, 1988 U.S. Dist. LEXIS 7047
CourtDistrict Court, Virgin Islands
DecidedMay 17, 1988
DocketCrim. Nos. 1988/5, 1988/7
StatusPublished
Cited by4 cases

This text of 684 F. Supp. 1324 (Government of the Virgin Islands v. Frett) is published on Counsel Stack Legal Research, covering District Court, Virgin Islands primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Government of the Virgin Islands v. Frett, 684 F. Supp. 1324, 23 V.I. 433, 1988 WL 52271, 1988 U.S. Dist. LEXIS 7047 (vid 1988).

Opinion

O’BRIEN, Chief Judge

MEMORANDUM OPINION

The issue before us exists because of this Court’s unique jurisdiction to hear both federal and territorial criminal matters. We decide whether a violation of 18 U.S.C. § 922(g) is subject to the enhancement provisions of 18 U.S.C. § 924(c) when it occurred during a “crime of violence” not otherwise punishable by federal law. We hold that it does not, and we will sentence accordingly.

I. FACTS

The defendant, Howard James was tried with two co-defendants, Antonio Frett and Elias Petersen on multiple counts arising from a firearms incident which occurred at the Ralph de Chabert Project *435 on St. Croix. 1 This altercation resulted in a 5 count information being brought by the Government of the Virgin Islands against James, two counts of which were for assault with intent to commit murder in violation of 14 V.I.C. § 295(1); 2 and one count of which was for assault which inflicted bodily harm in violation of 14 V.I.C. § 297(4). 3 The final two Virgin Islands counts were for unauthorized use and possession of unlicensed firearms during a crime of violence in violation of 14 V.I.C. § 2253(a), (b). 4 Additionally, the United *436 States of America brought a one count charge against James for the unauthorized possession of a firearm transported in interstate commerce in violation of 18 U.S.C. § 922(g), 5 for which it seeks to apply the enhanced penalty provision of 18 U.S.C.A. § 924(c)(1). 6

*437 The jury returned guilty verdicts upon all five territorial counts and the sole federal charge. It specifically found that James was in possession of a machine gun as defined by both territorial and federal law.Thereafter, the parties briefed the sentencing issue and the Government of the Virgin Islands brought an habitual criminal information against James pursuant to 14 V.I.C. § 61.

James now challenges the application of the enhanced penalty provision of 18 U.S.C. § 924(c) for want of a conviction of a “federal crime of violence” cognizable in the courts of the United States. The United States of America seeks application of § 924(c)(1) suggesting that the conviction under § 922(g) satisfies the federal crime of violence component of § 924(c), and that in any case, we may resort to James’ territorial convictions for establishment of the “crime of violence” component. We address the issue at length because if applicable, § 924(c) would appear to mandate us to sentence James to a 10-year sentence to run consecutively with the sentence imposed upon the territorial convictions. 7

II. DISCUSSION

The operative language of 18 U.S.C. § 924(c) provides for enhanced punishment for incidents involving the use or possession of a firearm (here, machine gun) during a “crime of violence.” As relevant to this case, a crime of violence is a felony, that “. . . has as an element the use ... of physical force against the person . . .” and which “. . . may be prosecuted in a court of the United States.” See supra, note 6. Such language appears straightforward.

However, as applied to a certain class of cases prosecuted in this Court, to which the case at bar belongs, there is ambiguity with respect to the meaning of the phrase “may be prosecuted in a court of the United States.” This is because the District Court of the Virgin Islands is not a United States District Court; Esposito v. *438 Barnard, 842 F.2d 393 (3d Cir. 1988) (en banc); nor is it defined as a court of the United States by the U.S. Code. See 28 U.S.C.A. § 451 (1968). It does possess all the jurisdiction of a United States District Court in addition to its jurisdiction over offenses against local law. 48 U.S.C.A. § 1612 (Supp. 1987). Thus, when as in this case, an accused stands trial before us simultaneously on unmerged federal and territorial counts arising out of the same incident, the issue is whether the language “may be prosecuted in a court of the United States” encompasses a crime of violence against the laws of the Virgin Islands which may be prosecuted in the District Court of the Virgin Islands. 8

The U.S.A. contends that we need not resolve this question because James’ violation of § 922(g) is a “crime of violence” within the meaning of § 924(c)(3) especially in light of the violent behavior in this case. We reject this contention. In United States v. Cruz, 805 F.2d 1464 (11th Cir. 1986), cert. denied, 481 U.S. 1006, 107 S.Ct. 1631 (1987), the Eleventh Circuit made a careful analysis of the statutory phrase “crime of violence”, using all of the statutory tools of construction after finding the phrase ambiguous. In so doing, it rejected a case by case approach urged by the government in that case, and similar to that urged by the U.S.A. here. Additionally, it rejected an argument put forward by the defendant Cruz, and proposed here by James, that we must look to whether the predicate crime of violence necessarily requires the use of force. Id. at 1469-70.

We conclude likewise that the phrase “crime of violence” is hopelessly ambiguous and we need only refer to the Cruz court’s discussion to suggest why. 805 F.2d at 1469-75. Little legislative history, no case law and unclear language leaves us with no understanding of Congressional intent. All we have is a short statement in the legislative history suggesting that Congress had in mind similar incidents as punished by state law, i.e., assault and battery. 1984 Cong, and Ad. New 3487. Yet this does not tell us whether possession itself in violation of § 922(g) is sufficient to require enhancement under § 924 when it occurs during a crime of violence punishable only by local law. Common sense tells us that it does not simply because it would make James accountable for *439 possession of a firearm during a crime of violence that the laws of the United States are not particularly interested in sanctioning.

This does not trouble the U.S.A. It refers us to United States v. Gironda, 758 F.2d 1201 (7th Cir. 1985), cert. denied, 481 U.S. 1006, 106 S.Ct. 523 (1986).

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Bluebook (online)
684 F. Supp. 1324, 23 V.I. 433, 1988 WL 52271, 1988 U.S. Dist. LEXIS 7047, Counsel Stack Legal Research, https://law.counselstack.com/opinion/government-of-the-virgin-islands-v-frett-vid-1988.