United States Third Circuit

Directed verdict judgment of the Supreme Court of the Virgin Islands for defendants in plaintiff's libel suit is affirmed, where: 1) although the court misapplied independent appellate review, it correctly held that plaintiff, a judge formerly on the Virgin Islands Superior Court, cannot establish actual malice for his libel claims; and 2) this plenary review makes any potential error from the alleged bias of the Supreme Court justices harmless, and thus the question whether the Supreme Court justices should have recused themselves need not be addressed.

Appellate Information

• Decided 03/08/2013
• Published 03/08/2013

Judges

• SMITH

Court

• United States Third Circuit

Counsel