## Facts

- Enrique Garcia was found dead on March 23, 1978, near Juan Ascencio Roldan’s property, with multiple stab wounds that caused death.
- Investigators found blood in and around Roldan’s house, on clothing, and on Roldan’s person.
- A blood-stained machete consistent with the autopsy description of the weapon was found atop an outhouse in Roldan’s yard.
- At trial, the defense cross-examined Luz Maria Cruz (wife of Roldan’s nephew) and elicited testimony portraying Roldan as peaceful and nonviolent, including that he “never bother[ed] anybody.”
- The court ruled that this testimony placed Roldan’s character in issue; after defense counsel declined to retract the question or strike the answer, the prosecutor was permitted on redirect to ask whether Cruz knew Roldan had previously been convicted of first-degree murder.
- The jury convicted Roldan of first-degree murder under V.I. Code tit. 14, § 922(a)(1), and he received a life sentence.

## Issues

1. Whether the trial court erred by allowing the prosecution, on redirect, to elicit testimony that Roldan had a prior first-degree murder conviction after the defense elicited testimony suggesting he was peaceful and harmless.
2. Whether the evidence was sufficient to permit a rational jury to find the “premeditation and deliberation” required for first-degree murder under § 922(a)(1).

## Decision

- The Third Circuit affirmed the conviction and sentence.
- The court held the trial judge did not err in permitting redirect questioning about the prior murder conviction because the defense placed Roldan’s character in issue and refused to cure the testimony.
- The court held the circumstantial evidence was sufficient for a rational jury to find premeditation and deliberation beyond a reasonable doubt.

## Legal Principles

- The prosecution generally may not introduce character evidence to show action in conformity with that character.
- When the defense introduces evidence of the defendant’s good character, the prosecution may rebut or impeach that character evidence.
- Trial courts have discretion to control the scope and form of rebuttal impeachment once the defense places character in issue.
- On sufficiency review, the evidence is viewed in the light most favorable to the prosecution; the conviction stands if any rational juror could find the elements beyond a reasonable doubt.
- Multiple wounds and conduct consistent with concealing the weapon can support an inference of premeditation and deliberation.

## Conclusion

The conviction was affirmed because the defense elicited broad testimony implying Roldan’s peaceful character, permitting limited rebuttal through evidence of a prior murder conviction, and because the physical and circumstantial evidence supported the jury’s finding of premeditation and deliberation for first-degree murder.


Government of the Virgin Islands v. Roldan, 612 F.2d 775 (3d Cir. 1979)