People v. Smith

59 V.I. 13, 2010 V.I. LEXIS 100
CourtSuperior Court of The Virgin Islands
DecidedNovember 5, 2010
DocketCase No. SX-07-CR-041
StatusPublished

This text of 59 V.I. 13 (People v. Smith) 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. Smith, 59 V.I. 13, 2010 V.I. LEXIS 100 (visuper 2010).

Opinion

DONOHUE, Presiding Judge

MEMORANDUM OPINION

(November 5, 2010)

BEFORE THE COURT is Defendant Teddy B. Smith’s Motion for Mistrial. Assistant Attorney General Melissa P. Ortiz appeared on behalf of the People of the Virgin Islands. Defendant appeared personally and through counsel, Attorney Warren B. Cole. For the reasons that follow, the Court will grant Defendant’s Motion for Mistrial.

I. BACKGROUND

Defendant is charged with one count of aggravated rape in the first degree in violation of section 1700(b) of title 14 of the Virgin Islands Code, two counts of rape in the first degree in violation of section 1701(2) of title 14 of the Virgin Islands Code, and three counts of assault in the first degree in violation of section 295(3) of title 14 of the Virgin Island Code. (Information, filed Feb. 14, 2007.)

Jury selection commenced on Monday, August 16, 2010, at approximately 11:00 a.m. One-hundred and one citizens from St. Croix were called for the venire. The Court conducted voir dire examination of the venire and excused approximately fifty-three jurors for cause. In advance of jury selection, and again near the end of voir dire, the Court requested and allowed the Parties to submit additional questions to ask of the venire, pursuant to Federal Rule of Criminal Procedure 24(a)(2)(B). The People did not submit any additional questions. Defendant submitted proposed questions twice, (see Def. Proposed Voir Dire, filed Aug. 11, 2010; Def. Proposed Jury Panel Voir Dire Questions, filed July 30, 2007), from which the Court, after consulting both parties, selected two additional questions to ask the venire. No further excusáis occurred because of Defendant’s questions.

[18]*18After voir dire concluded, the Court asked the Parties to approach the bench to discuss for cause and peremptory challenges. Defendant challenged one juror for cause, which the Court subsequently denied. The People had no challenges for cause. Next, the Parties exercised peremptory challenges; the People struck six prospective jurors and the Defendant struck ten, as allotted by Federal Rule of Criminal Procedure 24(b)(2).

At the conclusion of the Parties’ peremptory challenges, Defendant noted that the People had exercised all six of their peremptory challenges to strike only males from the petit jury. Defendant then moved for mistrial. In response, the People countered that their strikes were constitutionally valid. The Court reserved ruling on the motion, empanelled the jury and excused them for lunch, and then dismissed the remaining venire members. The Court then heard arguments from both Parties on Defendant’s motion.

Defendant claims that the People struck jurors peremptorily based solely on their gender, in violation of his right to a fair and impartial jury as guaranteed under the Due Process and Equal Protection Clauses of the Fourteenth Amendment to the United States Constitution.1 The People claimed, as discussed further below, non-discriminatory bases for the exercise of their peremptory strikes. At the conclusion of the Parties’ arguments, Defendant’s attorney, after consultation with his client, decided not to move for a mistrial because Defendant, incarcerated since his arrest in 2007, was anxious to proceed to trial. Upon reconvening after lunch recess, the Court instructed the jury on their role in the trial and adjourned for the day.

Before trial reconvened the next morning, the Parties again met at Defendant’s request to address further his motion for mistrial. Defendant’s counsel indicated that Defendant had taken the evening to think the matter through further, and that upon reflection decided to exercise his right to move for mistrial based upon the People’s exercise of their peremptory strikes. For the reasons that follow, the Court granted Defendant’s motion, declared a mistrial, and dismissed the jury.

[19]*19II. DISCUSSION

The privilege of striking individual jurors through peremptory challenges “is subject to the commands of the Equal Protection Clause.” Batson v. Kentucky, 476 U.S. 79, 89, 106 S. Ct. 1712, 90 L. Ed. 2d 69 (1986). Striking a juror peremptorily based solely on his gender, and nothing more, violates the Equal Protection Clause and is, therefore, unconstitutional. J.E.B. v. Alabama ex rel T.B., 511 U.S. 127, 129, 114 S. Ct. 1419, 128 L. Ed. 2d 89 (1994). This is because, “whether the trial is criminal or civil, potential jurors, as well as litigants, have an equal protection right to jury selection procedures that are free from state-sponsored group stereotypes rooted in, and reflective of, historical prejudice.” Id. at 128. As a protection afforded by the United States Constitution, prohibitions on gender-based peremptory strikes apply with the same force and effect in courts in the U.S. Virgin Islands as in any other court in the United States, though here through the protections afforded by the Revised Organic Act. Rev. Org. Act § 3 (1954) (codified as amended at 48 U.S.C. § 1561 (2000)) (applying the protections of Section 1 of Fourteenth Amendment to the Territory).

Courts conduct a three-part test when examining challenges to a party’s use of their peremptory strikes. Hardcastle v. Horn, 368 F.3d 246, 255 (3d Cir. 2004). First, the party alleging the intentional discrimination in the exercise of a peremptory challenge must make a prima-facie showing of that purported discrimination. J.E.B., 511 U.S. at 145. Defendant may base his prima facie case entirely on the actions of the prosecutor. Hardcastle, 368 F.3d at 255. Once the challenging party articulates his prima facie case of discrimination, the Court must determine whether that showing does, in fact, meet the requirements of a prima facie showing. See generally Hernandez v. New York, 500 U.S. 352, 359-60, 111 S. Ct. 1859, 114 L. Ed. 2d 395 (1991). Courts employ a five-part test in determining whether a Defendant has met the prima facie showing. See, e.g., Deputy v. Taylor, 19 F.3d 1485, 1492 (3d Cir. 1994). This requirement of a prima facie showing is “a threshold requirement before the court is to call upon the state to explain its challenge; the defendant must show that there is ‘some reason to believe that discrimination might be at work.’ ” Johnson v. Love, 40 F.3d 658, 663 (3d Cir. 1994) (quoting United States v. Clemmons, 892 F.2d 1153, 1156 (3d Cir. 1989)).

[20]

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59 V.I. 13, 2010 V.I. LEXIS 100, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-smith-visuper-2010.