People of the Virgin Islands

CourtSuperior Court of The Virgin Islands
DecidedNovember 2, 2020
DocketST-17-CR-31
StatusUnpublished
Cited by1 cases

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Bluebook
People of the Virgin Islands, (visuper 2020).

Opinion

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST THOMAS AND ST JOHN

) PEOPLE OF THE VIRGIN ISLANDS ) ) Plaintiff ) ) CASE NO ST 17 CR 031 v ) ) JEHRELLE ASTER WARNER ) ) Cite as 2020 VI Super 92U Defendant ) ) MEMORANDUM OPINION ‘F 1 THIS MATTER is before the Court on the People of the Virgin Islands’ Motion to Allow

Witness to Appear via Skype or Other Electronic Real Time Medium at Trial, filed on October 21,

2019 Defendant filed an Opposition on October 23, 2019 The Court held a pretrial conference on

October 20, 2020, where the parties informed the Court that they continue to hold the same views

expressed in their motions, regardless of the onset of the COVID 19 pandemic For the reasons set

forth below, the Court will grant the People’s motion

1 Factual Background

11 2 Defendant Warner was been charged with various violations of the criminal code in

connection with an incident where she allegedly crashed into Wolfgang and Monika Goldammer with

her vehicle The incident occurred when the couple was visiting St Thomas, Virgin Islands on a

cruise The record reflects that Mrs Goldammer was pushing Mr Goldammer across a crosswalk in

his wheelchair when they were struck by Defendant’s vehicle Mr Goldammer later died from his

injuries, but Mrs Goldammer was not seriously injured Mrs Goldammer is approximately seventy

five (75) years old and lives in Germany; she is also the People’s primary witness The People, even

pre pandemic, sought the Court’s permission to allow Mrs Goldammer to testify via electronic

medium on the grounds that she could not travel due to post traumatic stress disorder associated with People v Jehrelle Aster Warner Cite as 2020 VI Super 92U Case No ST 17 CR 031 Memorandum Opinion

the incident and her age The parties arguments remain the same, but the People’s position now

appears much stronger because of the COVID l9 pandemic

II The Confrontation Clause

1] 3 Defendant Warner opposes the remote testimony of Mrs Goldammer on the grounds that it

violates her Sixth Amendment right to confront adverse witnesses Def ’5 Opp’n 2 The Sixth

Amendment applies to the Virgin Islands through section 3 of the Revised Organic Act of 1954 and

guarantees a criminal defendant the right ‘to be confronted with the witnesses against him ”US

Const amend VI The Revised Organic Act contains a parallel provision, which the Virgin Islands

Supreme Court has not, to date, interpreted differently than the Sixth Amendment Murrell v People

0fthe VI 54 VI 338 354 (VI 2010)‘ bulsee Balbom v Ranger Am ofthe V.[ Inc 70 VI 1048

1089 (VI 2019) (holding that the Virgin Islands Supreme Court has the power to interpret the

Revised Organic Act’s Bill of Rights as providing greater protection for individual rights than the

United States Constitution)

1] 4 The Confrontation Clause affords criminal defendants both the right to confront and to cross

examine adverse witnesses ” Browne v People ofthe VI , 56 V I 207, 221 22 (V I 2012) However,

the right like many has limitations In Maryland v Crazg 497 U S 836 (1990) the United States

Supreme Court held that allowing child sexual abuse victims to testify in a separate room where the

defendant could see them via a one way monitor did not run afoul of the Sixth Amendment [d at

851 52 It stated that the Confrontation Clause reflects a preference for face to face confrontation,’

which “must occasionally give way to considerations of public policy and the necessities of the

case ’ 1d at 849 Confrontation rights may be satisfied absent a physical, face to face confrontation

at trial only where denial of such confrontation is necessary to timber an important public policy and

only where the reliability of the testimony is otherwise assured ” Id at 850

2 People v Jeltrelle Aster Warner Cite as 2020 v1 Super 9211 Case No ST 17 CR 03! Memorandum Opinion

15 Courts have relied on this holding to permit live remote testimony in various contexts,

including where the witness 3 health and safety might be compromised by testifying in person See

Lmted States v Gigante 166 F 3d 75 79 (2d Cir 1999) (allowing elderly witness to testify from a

remote location while in witness protection program), see also Unzted States v Donz:ger, No 19 CR

561 (LAP) 2020 U S Dist LEXIS 157797 at *5 6 (S DN Y Aug 31 2020) (allowing testimony

by two way video because “limiting the spread of COVID l9 and protecting at risk individuals from

exposure to the virus are critically important public policies”); Virgin Islands v Tranberg, 28 V I 52,

55 (V I Terr Ct 1993) (finding that allowing a victim of elder abuse to testify by video would be

analogous to the procedure used for child sex abuse victims) However, courts have recognized that

under C ralg the government must show not only that remote testimony serves an important public

policy, but that it is necessary, meaning there are no alternatives (mired Srates v Pangelman, No

19 10077 JWB 2020 U S Dist LEXIS 157465 at *7 (D Kan Aug 31 2020) (declining to allow

healthy witnesses testify remotely during COVID 19 pandemic); United States v Casher, No CR

19 65 BLG SPW 2020 U S Dist LEXIS 106293 at *8 (D Mont June 17 2020) (requiring witness

to testify in person during COVID l9 pandemic because he could travel by vehicle to courthouse and

avoid the increased exposure associated with air travel)

'16 When allowing remote testimony, courts have evaluated whether the underlying goals of

confrontation would still be met without live in court testimony “The main and essential purpose of

confrontation is to secure for the opponent the opportunity of cross examination ” George v People

0fthe VI 59 VI 368 380 (VI 2013) (quoting Dams v Alaska 415 US 308 315 16 (1974))

Another central “purpose of the Confrontation Clause is to ensure the reliability of testimony by

permitting the jury to draw conclusions from the manner and demeanor of the witness ” Cascen v

3 People v Jehrelle Aster Warner Cite as 2020 v1 Super 92v Case No ST 17 CR 031 Memorandum Opinion

People of the VI 60 VI 392 412 (V I 2014) (quoting Untied States v de Jesus Casteneda 705

F 3d 1117 1120 n 3 (9th Cir 2013)) Considering these rationales courts have found that

[A]llowing a prosecution witness to testify during a criminal trial by two way video conference or two way closed circuit television does not violate the defendant s right to confront the witnesses against them where doing so is necessary to protect the health or well being of the witness or someone else, and the defendant is able to cross examine and confront the witness through the video platform

Commonu ealth v Masa No 1981CR0307 2020 Mass Super LEXIS 109 at *5 (Aug 10 2020)

(collecting cases)

[I] Remote Testimony by Mrs Goldammer

1] 7 This Court finds that allowing Mrs Goldammer to testify by live two way video does not

violate Defendant Warner s right to confrontation Under Craig, the Sixth Amendment is satisfied by

something other than live face to face confrontation if it is necessary to further an important public

policy and the reliability of the testimony is assured 497 U S 850 The Court finds that preventing

the spread of COVID 19 and not subjecting Mrs Goldammer, who is an at risk individual, to a

possible infection is an important public policy that can only be served by allowing remote testimony

in this situation Donzzger 2020U S Dist LEXIS 157797 at *5—6 Masa 2020 Mass Super LEXIS

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People of the Virgin Islands v. Jehrelle Aster Warner
Superior Court of The Virgin Islands, 2020

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