Wednesday, December 18, 2013

Government of the Virgin Islands v. Knight case brief

Government of the Virgin Islands v. Knight case brief summary
989 F.2d 619 (3d Cir. 1993)


CASE SYNOPSIS
Defendant appealed from the judgment of the United States District Court for the District of the Virgin Islands, which entered a conviction for voluntary manslaughter, possession of a firearm during the commission of a crime of violence, and possession of a firearm by felon, adjudged him to be a habitual criminal, and enhanced his sentence pursuant to 14 V.I. Code Ann. § 61 (1990).

CASE FACTS
Defendant was found guilty of voluntary manslaughter, possession of a firearm during the commission of a crime of violence, and possession of a firearm by a felon. The district court adjudged defendant a habitual offender and enhanced his sentence pursuant to 14 V.I. Code Ann. § 61 (1990).

DISCUSSION

  • On appeal, the court affirmed the conviction and the sentence. 
  • The court held that the district court did not abuse its discretion by finding that defendant's explanation failed to establish cause for the late filing of his notice of intent to assert an insanity defense under Fed. R. Crim. P. 12.2(a). 
  • The district court's error in excluding an eyewitness' and an investigating officer's testimony that the firing of the gun was an accident did not prejudice defendant because the witness was permitted to describe fully the circumstances that led to his opinion. 
  • The court held that no evidence supported the conclusion that defendant reasonably believed he was in imminent danger of harm at the time of the assault. 
  • Thus, the district court properly declined to include a jury charge on excusable homicide. 
  • The court ruled that sentencing under the enhancement statute was proper.

CONCLUSION
The court affirmed the judgment of the district court finding defendant guilty of voluntary manslaughter, possession of a firearm during the commission of a crime of violence, and possession of a firearm by felon, and sentencing him as a habitual offender because the district court did not commit prejudicial error in excluding certain eyewitness testimony and it properly declined to include a jury charge on excusable homicide.

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