People v. Morton

57 V.I. 72, 2012 WL 3204668, 2012 V.I. LEXIS 38
CourtSuperior Court of The Virgin Islands
DecidedAugust 7, 2012
DocketCase No. ST-11-CR-194
StatusPublished
Cited by2 cases

This text of 57 V.I. 72 (People v. Morton) 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.

Bluebook
People v. Morton, 57 V.I. 72, 2012 WL 3204668, 2012 V.I. LEXIS 38 (visuper 2012).

Opinion

HOLLAR, Judge

MEMORANDUM OPINION

(August 7, 2012)

Before the Court is Defendant Jamal Morton’s Motion With Points and Authorities for Judgment of Acquittal, Arrest of Judgment or in the [75]*75Alternative a New Trial. The People filed an opposition in response thereto on June 7, 2012. For the reasons set forth below, the Defendant’s motion shall be denied.

I. PROCEDURAL POSTURE

On May 21, 2012, jury selection and trial commenced in the matter styled People of the Virgin Islands v. Jamal Allister Morton, and docketed at Case No. ST-ll-CR-194. At the conclusion of the People’s case-in-chief on May 22, 2012, Counsel for Defendant Morton made an oral “Rule 29 Motion” seeking dismissal of all counts in the Information.1 Arguments were heard from opposing counsels and the Court subsequently denied the motion. On May 23, 2012, deliberations concluded and the jury returned a verdict of guilty against Defendant Jamal Morton on the following charges: (1) the lesser-included offense of Count I, Second Degree Murder; (2) Unauthorized Use of a Firearm During the Commission of Second Degree Murder; (3) the lesser-included offense of Count III, Third Degree Assault; (4) Unauthorized Use of a Firearm During the Commission of Third Degree Assault; and (5) Reckless Endangerment in the First Degree.

II. STANDARD OF REVIEW FOR A MOTION FOR JUDGMENT OF ACQUITTAL

Rule 29(c) of the Federal Rules of Criminal Procedure allows the Court, where appropriate, to set aside a guilty verdict and enter an acquittal on the defendant’s behalf.2 A defendant may move for a judgment of acquittal, or renew such motion, “within 14 days after a guilty verdict.”3 A judgment of acquittal must be entered for any offense for which the evidence is insufficient to sustain the conviction.4

[76]*76When a defendant challenges the sufficiency of the evidence presented at trial, the Court must review the evidence in the light most favorable to the People.5 If any rational jury could find, beyond a reasonable doubt, that the People proved each element of the offense for which the defendant seeks acquittal, the conviction must be affirmed.6 Under this particularly deferential standard of review, the court is “prohibited from weighing the evidence or determining the credibility of witnesses”7 and “must be ever vigilant. . . not to usurp the role of the jury.”8 Accordingly, a finding of insufficiency should be “confined to cases where the prosecution’s failure is clear”9 and “[ojnly when the record contains no evidence, regardless of how it is weighed, from which the jury could find guilt beyond a reasonable doubt,” may the court overturn the jury’s verdict.10

III. STANDARD OF REVIEW FOR A MOTION FOR ARREST OF JUDGMENT

An arrest of judgment may be permitted pursuant to Federal Rule of Criminal Procedure 34. Generally, the rule prescribes that the court must, sua sponte or upon motion by the defendant, arrest judgment if the Information fails to charge an offense, or if the court lacks jurisdiction over the charged offenses.11 A motion for an arrest of judgment filed “within 14 days after the court accepts a verdict or a finding of guilty” is considered timely under the stated rule.12

[77]*77IV. STANDARD OF REVIEW FOR A MOTION FOR A NEW TRIAL

Superior Court Rule 135, in conjunction with Rule 33 of the Federal Rules of Criminal Procedure, governs motions for a new trial within the Superior Court of the Virgin Islands. Pursuant to Rule 135 of the Rules of the Superior Court, a motion for a new trial based on grounds other than newly discovered evidence “shall be made within 10 days after finding of guilty.”13 “Upon the motion, the court may vacate any judgment and grant a new trial if the interest of justice so requires.”14 Unlike a motion for a judgment of acquittal, a motion for a new trial calls upon the reviewing court to “weigh the evidence rather than examine its sufficiency and in doing so, it may weigh the credibility of witnesses.”15

The decision to grant a new trial is squarely within the Court’s sound discretion.16 Motions for new trials, however, are generally not favored and therefore,17 should not be granted unless there is a serious danger that an innocent person has been convicted.18 Thus, while a trial court may exercise its discretion and order a new trial, its discretion should be utilized only in exceptional circumstances where it finds that the evidence preponderates heavily against the verdict.19

V. ANALYSIS

This Court is asked to resolve the following: (1) whether the evidence, when viewed in the light most favorable to the People, was sufficient to sustain Defendant Morton’s verdict of guilt for the offenses charged; (2) whether Defendant Morton is entitled to an arrest of judgment; and (3) whether the weight of the evidence presented at trial supports the jury’s verdict of guilt.

[78]*78A. There Was Sufficient Evidence Presented By the People to Sustain a Jury’s Verdict of Guilt Beyond a Reasonable Doubt of the Crimes Charged in the Information.

On June 6, 2012, Defendant Morton timely filed his request for judgment of acquittal pursuant to Rule 29 of the Federal Rules of Criminal Procedure. Defendant’s post-trial motion under Rule 29 challenges whether the evidence presented to the jury was sufficient to support his convictions beyond a reasonable doubt. “The burden on a defendant who raises a challenge to the sufficiency of the evidence is extremely high”20 as the jury’s verdict “must be sustained if there is substantial evidence, taking the view most favorable to the [People], to support it.”21

1. Second Degree Murder: The Lesser-lncluded Offense of Count I of the Information.

The jury’s verdict finding Defendant Jamal Morton guilty of Second Degree Murder is supported by substantial evidence. Second Degree Murder, as defined in Title 14, Sections 921 and 922 of the Virgin Islands Code, is the “unlawful killing of a human being with malice aforethought.” To act with malice aforethought does not imply only acts of hatred or particular ill will, but the term also “extends to and embraces generally the state of mind with which one commits a wrongful act.”22

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Related

Francis v. People
63 V.I. 724 (Supreme Court of The Virgin Islands, 2015)
Joseph v. People
60 V.I. 338 (Supreme Court of The Virgin Islands, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
57 V.I. 72, 2012 WL 3204668, 2012 V.I. LEXIS 38, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-morton-visuper-2012.