Case Caption: Steven Allen v. People of the Virgin IslandsCase Number: S. Ct. Crim. No. 2012-0069Date: 09/12/2013Author: Swan, Ive Arlington Citation: Summary:

Convictions for interfering with an officer discharging his duty and operating an unregistered vehicle are affirmed. Title 14 §1508 is not unconstitutionally vague as applied to this defendant's case, which involved a lawful vehicular stop because the required registration sticker was visibly absent from its windshield. Failure to register the vehicle and display the registration sticker on the car's front windshield is a violation of 20 V.I. §§ 331 and 334 and the authority of an officer to have a vehicle towed for failure to register it is well established. On this record, the Superior Court correctly found that the officer was discharging his duties when he ticketed the defendant for failing to have his car registered and was executing a community caretaking function by having the car towed after it was found to be in violation of Virgin Islands law. The defendant's argument that §1508 is in violation of §3 of the Revised Organic Act is not supported by any argument, nor did this defendant assert below that he was engaging in “lawful protest” against police misconduct when he ignored the officer's lawful order. Examining the totality of the evidence, both direct and circumstantial, and interpreting the evidence in the light most favorable to the government as the verdict winner, the evidence was sufficient for a reasonable trier of fact to find the defendant guilty beyond a reasonable doubt. The convictions are affirmed.

Attachment: Open Document or Opinion