Justia Hawaii Supreme Court Opinion Summaries

A defendant’s failure to take prescription medication does not constitute self-induced intoxication under Haw. Rev. Stat. 702-230, which precludes the defendant from relying on the defense of lack of penal responsibility due to a physical or mental disease, disorder or defect.Defendant, who was charged with assault in the second degree, presented the defense of lack of criminal responsibility as a result of disease, disorder, or defect. The circuit court found Defendant guilty, concluding that any disease, disorder, or defect Defendant was experiencing at the time of the assault was self-induced and the product of Defendant’s refusal to take his prescribed medication and his use of marijuana. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the circuit court’s judgment of conviction, holding that the circuit court’s holding that Defendant’s failure to take his medication caused his psychotic behavior was inconsistent with the plain language of section 702-230, which requires the introduction of substances into the body. View "State v. Eager" on Justia Law

After a jury trial, Defendant was found guilty of criminal trespassing in the first degree, terroristic threatening in the second degree, and assault in the third degree. Defendant appealed, arguing that the circuit court influenced his decision not to testify by intimidating him through the trial. The intermediate court of appeals (ICA) affirmed, concluding that the circuit court adequately advised Defendant of his rights and obtained a valid waiver of his right to testify. The Supreme Court reversed, holding that the record was insufficient to support a conclusion that Defendant’s waiver of the right to testify was voluntarily, intelligently, and knowingly made. View "State v. Kim" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) vacating Defendant’s conviction for operating a vehicle under the influence of an intoxicant (OVUII) in violation of Haw. Rev. Stat. 291E-61(a)(1), reversing Defendant’s conviction for OVUII in violation of Haw. Rev. Stat. 291E-61(a)(3), and remanding the case for a new trial.On appeal, Defendant argued that his conviction under section 291E-61(a)(1) should be reversed rather than vacated and remanded for a new trial. The Supreme Court disagreed and held (1) the ICA did not err in concluding that the charge was not fatally defective for failing to include the statutory definition of the term “alcohol” and in concluding that there was substantial evidence to support Defendant’s conviction under section 291E-61(a)(1); and (2) the district court’s admonishment of Defendant for his decision to pursue trial may have violated his constitutional rights to due process and against self-incrimination. View "State v. Nakamitsu" on Justia Law

In these consolidated cases (Garner and Kawashima), the Supreme Court held that the circuit court erred in determining that Regulation 5203 was a Haw. Rev. Stat. chapter 91 rule and in granting summary judgment in favor of Plaintiffs for their hourly back wages contract claims. Further, the court erred in finding in the Garner case that Plaintiffs were entitled to interest on their per diem and hourly back wages under Haw. Rev. Stat. 103-10.Plaintiffs in both cases - substitute and part-time temporary teachers (PTTs) who were employed by the State, Department of Education (DOE) - claimed they were underpaid by the State. In Garner, the circuit court awarded hourly back wages to Plaintiffs who worked in a part-time capacity and also awarded interest on both the per diem and hourly back wages owed. In Kawashima, the circuit court awarded the PTTs hourly back wages but ruled that the PTTs were not entitled to interest on their unpaid hourly wages. The Supreme Court reversed the judgment in Garner and affirmed in part and reversed in part the judgment in Kawashima, holding that Plaintiffs were not entitled to hourly back wages or interest on any back wages, whether per diem or hourly, under section 103-10. View "Kawashima v. State, Department of Education" on Justia Law

The Supreme Court reversed Defendant’s conviction of committing the offense of terroristic threatening in the second degree, rendered after a bench trial. On appeal, Defendant argued that his substantial rights were violated when, during closing argument, the prosecutor read a portion of the complainant’s prior statement to the police where its contents had not been admitted into evidence. The Supreme Court agreed that error occurred, holding that the error was not harmless beyond a reasonable doubt because the prior statement was clearly relevant to proving the terroristic threatening offense, the State’s case was enhanced by the statement, and the defense’s case was significantly prejudiced. The court remanded the case to the district court for further proceedings. View "State v. McGhee" on Justia Law

In eight separate criminal cases, International Fidelity Insurance Company issued eight separate powers of attorney (POAs) to either Ida Peppers of Freedom Bail Bond or Charles Fisher of AAA Local Bail Bonds to execute a bail bond on behalf of the defendants in each case. In each case, the bonded defendant failed to appear, and the circuit court entered a judgment and order of forfeiture of bail bond. The court provided notice of those judgments to the surety listed on the bonds. International Fidelity moved to set aside each of the forfeiture judgments, arguing that it did not receive notice of the judgments as required under Haw. Rev. Stat. 804-51. The circuit court denied the motions. The intermediate court of appeals (ICA) affirmed, concluding that due process and the requirements of section 804-51 were satisfied when notice of the forfeiture judgments were issued to Peppers or Fisher. The Supreme Court affirmed, holding that the ICA did not err (1) in determining that notice to International Fidelity of the forfeiture judgments was not required by due process or under section 804-51; and (2) to the extent the forfeiture judgments were ambiguous, they were entered against the sureties on the bond - Peppers or Fisher. View "State v. Nelson" on Justia Law

Christopher Haig and Myrna Murdoch, two beneficiaries of a testamentary trust created under the will of Samuel Damon, objected to the probate court’s approval of the trust’s accounts from 1999 to 2003. The intermediate court of appeals (ICA) affirmed the probate court’s judgment. Christopher and Myrna separately applied for a writ of certiorari asserting that their due process rights were violated when they were not granted access to documents disclosed to the court-appointed master by the trustees of the trust, which prevented them from making informed objections to the master’s reports regarding the trusts’ accounts during the relevant time period. The Supreme Court reversed, holding that the ICA erred in affirming the probate court’s approval and adoption of the master’s report without first granting the beneficiaries’ requests to access trust administration documents, in violation of the requirements of Haw. Rev. Stat. 560:7-303. View "In re Trust Created Under the Will of Samuel M. Damon" on Justia Law

The circuit court deprived Defendant of his right to confront and cross-examine the complaining witness (CW) as to her bias and motive by limiting the CW’s testimony on the subject of Defendant’s immigration status and whether the CW knew that Defendant could face deportation if he was arrested.Defendant was found guilty of terroristic threatening in the first degree. The offense arose from a domestic dispute between Defendant and his ex-girlfriend, the CW. The intermediate court of appeals affirmed the judgment of conviction. Defendant filed an application for writ of certiorari, challenging the circuit court’s decision to limit the CW’s testimony on cross-examination. The Supreme Court vacated the judgment of conviction and probation sentence and remanded the case to the circuit court for a new trial. View "State v. Acacio" on Justia Law

This case arose from the administration of two irrevocable trusts (together, the trusts) established by Richard and Rachel Ishida. The trusts named as beneficiaries the Ishidas’ daughters Jeri Wilson and Juney Ishida and their granddaughter Kaki Wilson, but the trusts expressly excluded the Ishidas’ third daughter, Deenie Kimora. Six years after they created the trusts the Ishidas requested rescission of both trusts, alleging that they did not intend to make the trusts irrevocable and that Jeri had wrongfully transferred ownership of property from one trust to herself. The probate court ordered the property transferred by Jeri returned to the trust but declined to rescind or reform the trusts. The intermediate court of appeals affirmed. The Supreme Court affirmed, holding (1) the probate court did not err in denying the Ishidas’ requested relief because the matter was within the court’s equitable discretion; and (2) the ICA properly found that the probate court was not required to accept at face value the Ishidas’ petitions, which were verified pursuant to Hawai’i Probate Rules Rule 5(a). View "In re Ishida-Waiakamilo Legacy Trust" on Justia Law

The intermediate court of appeals (ICA) erred in concluding that a challenge to the erroneous inclusion of prior convictions in a PSI cannot be brought on a Hawai'i Rules of Penal Procedure Rule 35 motion for post-conviction relief;The circuit court sentenced Stanley Kong to consecutive terms of imprisonment based on a presentence investigation report (PSI) that erroneously included two prior convictions that had been previously vacated and dismissed. Kong’s counsel did not, however, bring this fact to the circuit court’s attention. The Supreme Court affirmed the sentence in Kong I. Thereafter, Kong filed a motion under Rule 35(b) to reconsider or reduce sentence challenging the erroneous inclusion of the two prior convictions in his PSI. The circuit court denied the motion. The ICA affirmed. The Supreme Court vacated the ICA’s judgment on appeal and remanded, holding (1) the ICA erred in concluding that Defendant could not challenge, via a Rule 35 motion, the erroneous inclusion of the two prior convictions in his PSI; and (2) the circuit court erred by concluding that Kong I precluded its reevaluation of Kong’s sentence and by failing to address Kong’s challenge to the inclusion of the two vacated and dismissed prior convictions in his PSI. View "State v. Kong" on Justia Law