Justia Hawaii Supreme Court Opinion Summaries

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The Supreme Court held that when an officer administers a standardized field sobriety test (SFST) to a person suspected of operating a vehicle under the influence of an intoxicant, the officer is conducting an interrogation under the Hawai'i Constitution by asking "medical rule-out questions."Medical rule-out questions rule out other reasons besides intoxication for poor performance on the SFST. Defendant was asked seven medical rule-out questions while she was in police custody and before she was advised of her rights under Miranda v. Arizona, 384 U.S. 436 (1966). After Defendant was charged with OVUII she filed a motion to suppress, arguing that she was subjected to interrogation when the officer asked if she would like to participate in the SFST. The district court granted the motion. The ICA ruled that the district court erred by suppressing Defendant's response to whether she would participate in the SFST but that that the medical rule-out questions constituted interrogation. The Supreme Court affirmed, holding that the ICA did not err in concluding that Defendant's answers to the medical rule-out questions must be suppressed and that the other challenged evidence was admissible. View "State v. Skapinok" on Justia Law

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The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) vacating in part the district court's conclusion that Defendant's performance on the standardized field sobriety test (SFST) was inadmissible fruit of the poisonous tree, holding that Defendant's performance on the SFST was admissible despite the absence of Miranda warnings preceding the test.Defendant was subject to custodial interrogation during a roadside investigation for operating a vehicle under the influence of an intoxicant. At issue was whether the evidence gathered after that illegality, including his performance on the SFST was testimonial of fruit of the poisonous tree. The Supreme Court affirmed the admission of Defendant's performance on the SFST, holding that the police did not exploit the illegal interrogation because the interrogation did not lead to the discovery of the SFST evidence. View "State v. Manion" on Justia Law

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The Supreme Court vacated the order of the district court suppressing Defendant's statements, vacated the judgment of the intermediate court of appeals (ICA) affirming that Defendant was in custody during the traffic stop, and remanded this case for further proceedings, holding that Defendant was not entitled to suppression of her statements.Defendant was arrested after a traffic stop and charged with operating a vehicle under the influence of an intoxicant and excessive speeding. Defendant filed a motion to suppress statements she made during the traffic stop on the basis that she was not advised of her rights under Miranda v. Arizona, 384 U.S. 436 (1966), during the incident. The district court agreed and granted the motion. The ICA affirmed. The Supreme Court reversed, holding (1) under the totality of the circumstances, Defendant was not in custody when she was pulled over during the administration of the standardized field sobriety test; and (2) because Miranda warnings were not required, there was no illegality that would taint Defendant's subsequent statements as fruit of the poisonous tree. View "State v. Sagapolutele-Silva" on Justia Law

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The Supreme Court held that the 2021 Hawai'i Reapportionment Commission (the Commission) discharged its obligations under Haw. Const. art. I, 6 and Haw. Rev. Stat. 25-2(b) in developing the 2021 Final Legislative Reapportionment Plan.Petitioners, voters in the state, argued that the plan violated article I, section 6 because it did not reflect that "representative districts shall be wholly included within senatorial districts" and violated Haw. Rev. Stat. 25-2(b)(5) by placing nine O'ahu legislative districts into both congressional districts. The Supreme Court held that the Commission satisfied its obligations under article IV, section 6 and section 25-2(b) by considering the constitutional and statutory district within district guidelines in developing the plan and did not abuse its discretion in adopting the plan. View "Hicks v. 2021 Hawai'i Reapportionment Commission" on Justia Law

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The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court granting Defendant's motion to dismiss the felony information against him based upon a defective charge, holding that the ICA correctly determined that the State should have provided the statutory definition of "substantial bodily injury" in the charging document at issue.The State charged Defendant by felony information with the offense of assault in the second degree, in violation of Haw. Rev. Stat. 707-711(1)(a) and/or (d). Defendant filed a motion to dismiss, arguing that the felony information did not provide notice as to the definitions of "substantial bodily injury" or "dangerous instrument," and therefore the charge was defective. The circuit court granted the motion and dismissed the case. The ICA affirmed. The Supreme Court affirmed, holding (1) the State must include the statutory definition of "substantial bodily injury" in a charge of second-degree assault under section 707-711(a); and (2) the State waived its argument that discovery materials provided Defendant with actual knowledge of the charges against him. View "State v. Jardine" on Justia Law

Posted in: Criminal Law
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The Supreme Court held that, by and large, Hawai'i's public information law - the Uniform Information Practices Act (UIPA) - required the state Attorney General (AG) to release a report it issued in 2016 documenting deceptive practices, incompetence, and workplace bullying in the Office of the Auditor.After the state AG compiled a record of its investigation a reporter with the Honolulu Civil Beat, an investigative news organization, asked for the investigative reports pursuant to UIPA. The circuit court granted summary judgment in favor of the state AG, concluding that the report was exempt from the UIPA. The Supreme Court vacated the circuit court's final judgment, holding that, regarding the vast majority of the report, the UIPA's presumption favoring disclosure was not overcome. View "Honolulu Civil Beat Inc. v. Department of the Attorney General" on Justia Law

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The Supreme Court vacated in part the judgment of the intermediate court of appeals (ICA) to the extent it affirmed the circuit court's judgment as to the "Reinstated Hawaiian Nation," vacated the circuit court's final judgment as to the Reinstated Hawaiian Nation, and affirmed the circuit court's judgment as to all other defendants, holding that the circuit court erred in part.In 2011, Nelson Armitage and a group of others (collectively individual defendants), and Frederick Torres-Pestana, entered onto and began occupying land in Maui owned by Alexander & Baldwin, LLC (A&B). The individual defendants claimed they were acting on behalf of the organization called the Reinstated Hawaiian Nation. A&B brought suit seeking a writ of ejectment, damages, and injunctions barring the individual defendants and the Reinstated Hawaiian Nation from entering A&B's property. The circuit court granted summary judgment for A&B and entered an injunction. The ICA dismissed the appeal as to the Reinstated Hawaiian Nation and rejected Armitage's appeal individually. The Supreme Court vacated in part, holding (1) the judgment against the Reinstated Hawaiian Nation must be voided due to the public policy behind the prohibition on the unauthorized practice of law; and (2) the judgment against Armitage or any other defendant still stands. View "Alexander & Baldwin, LLC v. Armitage" on Justia Law

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In this case concerning the enforceability of a non-compete agreement the Supreme Court vacated the intermediate court of appeals' judgment on appeal and the circuit court's final order in favor of Lorna Gagnon with respect to her alleged breach of a non-solicitation clause as to one real estate agent but otherwise affirmed, holding that a genuine issue of material fact precluded summary judgment as to this issue.A non-compete agreement restricted Gagnon, a former employee of Prudential Locations, LLC, from establishing her own brokerage firm in Hawaii within one year after terminating her employment with Locations and from soliciting persons employed or affiliated with Locations. The Supreme Court held (1) the ICA erroneously failed to address whether the non-compete and non-solicitation clauses were ancillary to a legitimate purpose not violative of Haw. Rev. Stat. Chapter 480; (2) restricting competition is not a legitimate ancillary purpose; (3) to establish a violation of a non-solicitation clause, there must be evidence that the person subjective to the clause actively initiated contact; and (4) as to the non-compete clause, summary judgment was proper, but as to the non-solicitation clause, a genuine issue of material fact existed regarding whether Gagnon actively initiated contact. View "Prudential Locations, LLC v. Gagnon " on Justia Law

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The Supreme Court affirmed the decision of the intermediate court of appeals (ICA) affirming the judgment of the circuit court denying Defendant's motion to suppress evidence, holding that the police officers' actions did not constitute a breaking and that the search of a gray backpack did not exceed the terms of the search warrant in this case.On appeal, Defendant argued that the evidence against him should be excluded because police officers failed to comply with the requirements set forth in Haw. Rev. Stat. 803-37 that officers "demand entrance" before entering a building and because the search of his backpack exceeded the terms of the search warrant executed by the officers. The Supreme Court affirmed, holding (1) the purposes of Haw. Rev. Stat. 803-37 were satisfied when the officers' entry did not create any risk of harm; and (2) the searches of Defendant's backpack did not exceed the terms of the search warrant. View "State v. Keanaaina" on Justia Law

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The Supreme Court held that the authority of the Board of Land and Natural Resources (BLNR) to issue revocable permits is subject to the environmental review requirements of the Hawai'i Environmental Policy Act (HEPA), Haw. Rev. Stat. ch. 343.At issue was the water rights for 33,000 acres of land in the Ko'olau Forest Reserve and Hanawi Natural Area Reserve. In 2000, the BLNR approved the issuance of four revocable water permits to Alexander & Baldwin, Inc. (A&B) and East Maui Irrigation Co., Ltd. (EMI). The BLNR subsequently continued the permits. Petitioners brought this action alleging that the renewal of the revocable permits required the preparation of an environmental assessment pursuant to the HEPA. The circuit court granted summary judgment for Petitioners, concluding that the continuation decision was not a HEPA action but that the revocable permits were invalid because they exceeded the BLNR's authority under Haw. Rev. Stat. 171-55. The Supreme Court remanded the case, holding (1) the revocable permits were not authorized under section 171-55; and (2) the circuit court erred in holding that there was no "action" within the meaning of Haw. Rev. Stat. 343-5(a) and that HEPA's environmental review process was thus inapplicable. View "Carmichael v. Board of Land & Natural Resources" on Justia Law