Case Caption: Jeffrey Browne v. People of the Virgin IslandsCase Number: S. Ct. Crim. No. 2010-0069Date: 02/02/2012Author: Hodge, Rhys S. Citation: Summary:

In a prosecution on two counts of first degree murder and charges of attempted murder, assault, reckless endangerment, unauthorized possession of a firearm, and interference with an officer discharging his duties, there was no reversible error in the trial court's admission of evidence seized pursuant to a valid search warrant obtained after defendant's vehicle was allegedly impounded illegally, or in the court's admission of statements by a co-defendant (his wife) which was redacted to remove any mention of him, and did not bear testimony against him. The trial court's receipt into evidence of death certificates of two of the victims, without testimony from the medical examiner who authored them, was in violation of the Confrontation Clause under Crawford v. Washington, 541 U.S. 36 (2004) and Bruton v. United States, 391 U.S. 123 (1968), but this error was harmless beyond a reasonable doubt in the context of this case. The trial court also violated defendant's constitutional right to present a complete defense by excluding the proffered testimony of an attorney in an effort to impeach a government witness, but this error was also harmless beyond a reasonable doubt in light of other evidence. There was no reversible error in the trial court's handling of claims of juror misconduct, a motion for a change of venue, or its rulings relating to other rebuttal witnesses. The convictions and the judgment of the Superior Court are affirmed.

Attachment: Open Document or Opinion