judges — regardless of whether they are campaigning' — in order to promote the efficient administration of justice, is not an issue raised here.”); see also In re Vincent, 172 P.3d at 608 (“[E]valuating the constitutionality of restrictions on the political speech of a judge does not fit neatly into the existing analytical framework for First Amendment analysis. Selecting the appropriate framework for analysis has become even more difficult since White.”) Since that question is not implicated here, we leave it for another day. 10 . The Virgin Islands Supreme Court did not base Kendall's conviction on a conclusion that his words were defamatory. See Standing Comm. on Discipline of U.S. Dist. Court for Cent. Dist. of Cal. v. Yagman, 55 F.3d S. 6, 14, 90 S.Ct. 1537, 26 L.Ed.2d 6 (1970) (<HOLDING>). 11 . Count 2 charged Kendall with violating
holding that a description of a public figures negotiating position as blackmail could not be con strued as charging the plaintiff with committing a crime holding that a union newsletters description of a scab as a traitor could not be construed as a factual assertion holding that a district court may not rely on a charging document without first establishing that the crime charged was the same crime for which the defendant was convicted holding that an indictment is sufficient as long as it fully and clearly sets out the crime and the elements of the offense even if the evidence consists of proof of other means of committing the same crime recognizing that a court may look to the charging document in making a crime of violence determination but only where the statute provides disjunctive methods of committing the offense and the court needs to determine which of the statutory alternatives is involved in the particular case