Case Caption: Burgos v. Government of the Virgin IslandsCase Number: SCT-CIV-2020-0107Date: 04/17/2023Author: Hodge, Rhys S. Citation: 2023 VI 5Summary: In an convicted defendant’s appeal from the Superior Court’s denial of a petition for a writ of habeas corpus, relating to his arrest on December 30, 1993 and subsequent conviction in 1994 for first-degree murder, the Court here reviews the federal and territorial statutory developments in the history of jurisdiction over criminal proceedings by the United States District Court of the Virgin Islands, the former Territorial Court, and the Superior Court of the Virgin Islands. Construing Public Law 98-454 as well as the Virgin Islands Legislature’s implementing legislation in a manner consistent with legislative intent and which avoids absurd consequences, the District Court certainly possessed jurisdiction to try this defendant for first-degree murder despite the Superior Court being vested with such jurisdiction on January 1, 1994. Section 703(a) of Public Law 98-454 conferred upon the District Court jurisdiction “in all causes in the Virgin Islands the jurisdiction over which is not then vested by local law in the local courts of the Virgin Islands,” 48 U.S.C. § 1612(b), and section 703(b) expressly provided that these amendments “shall not result in the loss of jurisdiction of the District Court of the Virgin Islands over any complaint or proceeding pending in it on the day preceding the effective date of this amendatory Act” and “may be pursued to final determination in the District Court.” It is patently absurd to believe that either legislative body intended for no court to possess jurisdiction over first-degree murder cases between 1984 and 1994. Here, the criminal case against this defendant in the District Court commenced on December 30, 1993, and the expansion of the Superior Court’s jurisdiction and corresponding reduction of the District Court’s jurisdiction did not occur until January 1, 1994. Pursuant to section 703(b) of Public Law 98-454, the District Court was required to retain jurisdiction over all proceedings pending before it on the day prior to the effective date of that jurisdictional change, which was December 31, 1993. Therefore, the Superior Court correctly determined that the District Court possessed jurisdiction to try this defendant for first-degree murder and that his present petition for a writ of habeas corpus fails to set forth a prima facie case for relief. Accordingly, the Superior Court’s October 8, 2020 order denying habeas corpus relief is affirmed.Attachment: Open Document or Opinion