Justia Hawaii Supreme Court Opinion Summaries

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the district court's judgment finding Defendant guilty of resisting arrest, holding that Defendant was entitled to relief on his claim that his waiver of his right to a jury trial was not knowing, intelligent, and voluntary.Defendant signed a waiver form purporting to waive his right to a jury trial on the charge of resisting arrest. The district court accepted the waiver. After a bench trial, the court found Defendant guilty of resisting arrest and several other charges. The ICA affirmed. The Supreme Court vacated the judgments of the lower courts, holding (1) the record did not reflect a discuss and exchange sufficient to satisfy the district court's responsibility of ensuring a jury trial waiver's validity; and (2) under this Court's recent decision in State v. Ernes, 465 P.3d 763 (Haw. 2020), Defendant's waiver was not properly verified as knowing, intelligent and voluntary. View "State v. Voorhees " on Justia Law

Posted in: Criminal Law
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The Supreme Court held that, under the totality of the circumstances in this case, the results of Defendant's breath test were admissible because Defendant validly consented to the breath test.After police arrested Defendant for habitually operating a vehicle under the influence of intoxicants an officer read Defendant the Honolulu Police Department's (HPD) implied consent form. Defendant signed and initialed the form consenting to the breath test. Defendant filed a motion to suppress the results of the breath test, arguing that his consent was not knowing, intelligent, and voluntary because the form did not comply with the implied consent statutory scheme and was, therefore, inaccurate. The circuit court suppressed Defendant's breath test results. The intermediate court of appeals (ICA) vacated the circuit court's order, concluding that suppression of Defendant's breath test was not the proper remedy for non-compliance with Haw. Rev. Stat. Chapter 291E procedures. The Supreme Court affirmed, holding (1) the implied consent form here complied with Chapter 291E and was not inaccurate or misleading; and (2) only inaccuracies in implied consent forms that are reasonably likely to influence an arrestee to consent will require suppression. View "State v. Hosaka" on Justia Law

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In this original proceeding, the Supreme Court entered judgment dismissing this complaint asking the Court to nullify the results of the August 8, 2020 primary election for the City and County of Honolulu mayoral seat and allow all candidates who choose to continue to the November general election to have their names appear on the ballot, holding that the complaint failed to state claims upon which relief can be granted.Plaintiff was one of fifteen candidates for the City and County of Honolulu mayoral seat in the primary election. Rick Blangiardi and Keith Amemiya received the highest number of votes. Plaintiff brought this action alleging that their were multiple irregularities with the primary election. The Supreme Court dismissed the complaint, holding (1) the city clerk for the City and County of Honolulu was a necessary and indispensable party who should have been named as a defendant; and (2) in any case, the complaint failed to state claims upon which relief can be granted. View "Dicks v. State of Hawai'i Office of Elections" on Justia Law

Posted in: Election Law
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Given the rising number of COVID-19 cases at the O'ahu Community Correctional Center (OCCC) and the difficulties with social distancing the Supreme Court requested additional information to assist the court and parties in addressing the public health and safety concerns raised by the cluster of COVID-19 cases at OCCC.The Office of the Public Defender (ODP) filed a petition for extraordinary writ and/or a writ of mandamus seeking a reduction of the inmate populations at the State's correctional centers and facilities in an effort to mitigate the harm that COVID-19 may inflict upon the inmates, correctional staff, and general public. The Supreme Court stated that there was an urgent and immediate concern in reducing the inmate populations at OCCC and ordered that the DPS shall provide to the OPD a list of all inmates at OCCC who meet certain criteria. View "In re Individuals in Custody of State of Hawai'i" on Justia Law

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The Supreme Court affirmed the judgment of the intermediate court of appeals and the circuit court's judgment convicting Defendant of assault in the second degree, holding that the prosecutor's misconduct in this case violated Defendant's due process right to a fair trial.Defendant was convicted of assault in the second degree in connection with an incident involving Defendant's wife (CW). The only witnesses to the incident at the time the injury were Defendant and CW. During trial, the prosecutor made at least eight improper statements during closing argument, and the misconduct affected the central issue to Defendant's self-defense claim of whether he acted with the intent to protect himself. The Supreme Court remanded the case, holding that the strength of the evidence in support of self-defense, the protracted nature of the prosecutorial misconduct, and the court's ineffective curative instructions led to the conclusion that the misconduct was not harmless beyond a reasonable doubt. View "State v. Conroy" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the district court's judgment convicting Defendant of operating a vehicle under the influence of an intoxicant (OVUII), holding that the ICA gravely erred as a matter of law in finding that even if the district court erroneously allowed a police officer to opine that Defendant failed standardized field sobriety tests (SFSTs), the error was harmless.Specifically, the Supreme Court held (1) the district court erred by permitting Officer Joshua Wong to express an expert opinion that Defendant "failed" the SFSTs, and the error was not harmless beyond a reasonable doubt; (2) the district court erred in permitting expert opinion testimony that Defendant had a blood alcohol content of 0.08 or above; (3) the district court did not err in permitting expert opinion testimony that Defendant was intoxicated, but, prospectively, police officers may no longer testify, whether in a lay or expert capacity, that a driver appeared "intoxicated"; and (4) Defendant's conviction was supported by substantial evidence. View "State v. Jones" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed in part and vacated in part the circuit court's final judgment granting and apportioning monetary damages to Native Hawaiian beneficiaries after ruling that the State breached its duties as trustee of the Hawaiian Home Lands Trust (Trust), holding that the Fair Market Rental Value (FMRV) model is an adequate method for approximating actual damages.Plaintiffs were a group of Native Hawaiian Trust beneficiaries who claimed that they incurred damages while on the waitlist to receive homestead land due to breaches of trust duties by the State. In 2009, the circuit court ruled that the State breached its duties as trustee of the Trust. In 2018, the circuit court entered a final judgment adopting a FMRV model by which it could estimate the actual loss each individual beneficiary incurred. The Supreme Court affirmed in part and vacated in part the circuit court's judgment, holding that the circuit court (1) did not err by adopting the FMRV model; (2) incorrectly ruled that a beneficiary's damages did not begin to accrue until six years after the State received a beneficiary's homestead application; and (3) did not err in finding that the State breached its trust duties by failing to recover lands that were withdrawn from the Trust prior to statehood. View "Kalima v. State" on Justia Law

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The Supreme Court granted Defendants' petition for writ of mandamus, holding that the intermediate court of appeals (ICA) manifestly abused its discretion in setting the amount of a supersedeas bond as a condition of staying the enforcement of a judgment and writ of possession pending appeal.The circuit court granted summary judgment in favor of Plaintiff on its complaint for ejectment against Defendants. While Defendants' appeal was pending, Defendants moved for a stay of proceedings to enforce the judgment. The circuit court granted the request and required Defendants to post a supersedeas bond in the amount of $578,000. Defendants then filed a motion for a stay in the ICA. The ICA granted a stay on the condition that it would be effective upon the ICA's approval of a supersedeas bond in the amount of $250,000 (the stay order). Defendants filed a petition for writ of mandamus from the ICA's stay order, arguing that the amount of the supersedeas bond should not exceed $8,000. The Supreme Court granted the petition, holding (1) the ICA not apply relevant factors in setting the bond amount, and (2) the stay order lacked a reasonable timeframe in which Defendants would be required to post the bond. View "Kelepolo v. Fernandez" on Justia Law

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In this criminal case, the Supreme Court held prospectively that once the court receives notice pursuant to Haw. Rev. Stat. 407.5(1) that a defendant's penal responsibility is an issue in the case, the circuit court must advise a defendant of the penal-responsibility defense and obtain a knowing waiver of the defense.During the criminal proceedings in this case, two of the three examiners concluded that Defendant lacked penal responsibility. Defendant insisted that he was not mentally ill and that he did not want to assert a defense based on lack of penal responsibility. The circuit court eventually found Defendant was fit to stand trial, and Defendant was found guilty. On appeal, Defendant argued that the circuit court should have either sua sponte instructed the jury about the defense of criminal responsibility or conduct a colloquy to ensure that he knowingly and voluntarily decided not to raise the defense. The Supreme Court affirmed, holding that (1) going forward, courts have a duty to obtain a knowing and voluntary waiver of a penal-responsibility defense; and (2) the trial court followed the rules in place at the time of Defendant's conviction and had no duty to sua sponte instruct the jury on lack of penal responsibility. View "State v. Glenn" on Justia Law

Posted in: Criminal Law
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The Supreme Court held that Plaintiff's injury-by-disease was compensable under Hawai'i's workers' compensation law because the employer failed to overcome the presumption in favor of compensability.Plaintiff filed a workers' compensation claim for injury-by-disease. The Labor and Industrial Relations Appeals Board (LIRAB) rejected the claim, concluding that the employer's Independent Medical Examinations (IME) reports provided sufficient substantial evidence to overcome the statutory presumption in favor of compensability. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's judgment and the LIRAB's decision, holding that the employer's IME reports failed to provide substantial evidence to meet its burden to produce evidence that, if true, would overcome the statutory presumption that the injury was work-related. The Court remanded the case to the LIRAB with the instruction that Plaintiff's injury-by-disease was compensable under Hawai'i's workers' compensation law. View "Cadiz v. QSI, Inc." on Justia Law