Justia Hawaii Supreme Court Opinion Summaries

Defendant was arrested for operating a vehicle under the influence of an intoxicant (OVUII). Defendant was subsequently taken to the police station where she read an implied consent form, which conveyed a threat of imprisonment and significant punishment for refusal to submit to a breath, blood, or urine test. Defendant chose to take a breath test. Defendant was later convicted of OVUII. Defendant filed a motion to suppress the breath test result, arguing that she did not constitutionally consent to the breath test because her consent was coerced by the implied consent form. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment and remanded to the district court, holding that, in light of State v. Won, the result of Defendant’s breath test is the product of a warrantless search. View "State v. Tavares " on Justia Law

Defendant was convicted of entering or remaining in a public park during posted closure hours in violation of Honolulu ordinances. Defendant waived the “involvement” of a public defender after consulting with the public defender’s office before trial. The Intermediate Court of Appeals affirmed the conviction. The Supreme Court vacated Defendant’s conviction and remanded the case for a new trial, holding that Defendant’s waiver of his right to counsel was not knowingly and intelligently made, as the district court failed to conduct a formal inquiry regarding Defendant’s waiver of his right to counsel. View "State v. Deming " on Justia Law

Defendant was stopped by police officers while driving his vehicle and was subsequently arrested for operating his vehicle under the influence of an intoxicant. Defendant was asked to submit to a test for the purpose of determining alcohol concentration. The police informed Defendant of his right to refuse to consent to a bodily search but told him if he exercised that right, his refusal to consent would result in a potential thirty-day term of imprisonment. The intermediate court of appeals upheld Defendant’s blood alcohol concentration (BAC) test and the statutory scheme imposing sanctions for withdrawing consent. Defendant appealed, arguing that the BAC evidence in this case was obtained in an unconstitutional manner and should have been suppressed. The Supreme Court reversed, holding that the result of Defendant’s breath test, the product of a warrantless search, was not admissible into evidence because voluntary consent was not demonstrated, and no other exception to the warrant requirement was applicable. View "State v. Won" on Justia Law

A jury found Defendant guilty of committing robbery in the second degree. The jury was not required to find that Defendant had any prior convictions. The prosecution filed a post-conviction motion for the mandatory minimum term of imprisonment and introduced into evidence the judgment for Defendant’s prior convictions. The circuit court took judicial notice on file for both of Defendant’s prior convictions and granted the State’s motion for imposition of mandatory minimum period of imprisonment. Defendant appealed, asserting that, in accordance with Alleyne v. United States, a jury should have considered the facts alleged in the prosecution’s motion for imposition of a mandatory minimum sentence. The Intermediate Court of Appeals affirmed. The Supreme Court affirmed, holding (1) repeat offender sentencing under section 706-606.5 enhances the penalty of the crime committed, and therefore, a defendant’s predicate prior conviction(s) must be alleged in the charging instrument; (2) a jury is required to find that the defendant’s prior conviction(s) have been proved beyond a reasonable doubt to trigger the imposition of a mandatory minimum sentence under section 706-606.5; but (3) these rules are given prospective effect only. View "State v. Auld" on Justia Law

Petitioner was convicted for sex trafficking related crimes based on his conduct as a pimp for the complaining witness. Petitioner was present for voir dire and jury selection but failed to appear in court two days later despite instructions to do so. The trial was twice continued. After the second continuation, which lasted twenty-one days, the circuit court conducted trial in absentia. The intermediate court of Appeals (ICA) affirmed Petitioner’s conviction. The Supreme Court affirmed, holding (1) trial counsel did not provide ineffective assistance for failing to object to disjunctive charging language in jury instructions; and (2) the trial court did not violate Rule 43 of the Hawai’i Rules of Penal Procedure or violate Defendant’s right to be present at trial by proceeding with trial despite Defendant’s absence. View "State v. Vaimili" on Justia Law

After a jury trial, Defendant was found guilty of theft of the proceeds of sale of the home of an individual for whom she was acting as a caregiver, changing the name of ownership of two joint accounts, and taking $8,000 from the joint account to pay off Chin’s car. Defendant filed a motion for a new trial, arguing that the actions of a jury foreperson in communicating with a main defense witness about possible employment was highly prejudicial. The circuit court denied the motion, concluding that the nature of the alleged deprivation did not rise to the level of being substantially prejudicial. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment on appeal and the judgment of conviction and sentence, holding (1) in this case, the circuit court was required to investigate the circumstances surrounding the nontrivial communication between the defense witness and the juror; and (2) because the circuit court did not conduct such an investigation, it could not be said that Defendant’s fundamental right to a fair trial by an impartial jury was not compromised. Remanded for a new trial. View "State v. Chin" on Justia Law

After a jury trial, Defendant was found guilty of assault in the first degree and sentenced to ten years in prison. Defendant appealed, arguing that the circuit court abused its discretion in denying his motion to substitute retained counsel in place of his court-appointed counsel. The intermediate appellate court (ICA) affirmed the conviction and sentence, concluding that the circuit court did not abuse its discretion in denying Defendant’s motion. The Supreme Court vacated the ICA’s judgment on appeal and the circuit court’s judgment of conviction and sentence, holding that the circuit court abused its discretion in denying Defendant’s motion for withdrawal and substitution of counsel, resulting in the denial of Defendant’s right to privately retained counsel of choice under Haw. Const. art. I, 14. Remanded for a new trial. View "State v. Reed" on Justia Law

After a jury trial, Petitioner was convicted of terroristic threatening in the second degree and kidnapping. The Intermediate Court of Appeals affirmed Petitioner’s conviction and sentence. The Supreme Court reversed, holding that the circuit court erred in (1) instructing the prosecutor to inform the jury during closing arguments that the complaining witness was unavailable because she was dead - a fact not in evidence - and the error was not harmless beyond a reasonable doubt; and (2) admitting the complaining witness’s preliminary hearing testimony at trial in violation of Petitioner’s right to confrontation, and the error was not harmless. Remanded for a new trial. View "State v. Nofoa" on Justia Law

Plaintiff applied for a position with CDM Media, USA, Inc. Plaintiff was not hired for the position. Thereafter, Plaintiff filed a complaint alleging that CDM had decided not to hire her because of her age, and therefore, she had been subjected to employment discrimination. The circuit court granted summary judgment for CDM, concluding that Plaintiff had failed to demonstrate that CDM’s reasons for not hiring her were pretextual. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court vacated the judgments of the lower courts, holding that the trial court erred in granting summary judgment, as CDM did not satisfy its burden to produce a legitimate, nondiscriminatory reason for declining to hire Plaintiff. View "Adams v. CDM Media USA, Inc." on Justia Law

Defendant was indicted in counts I and III upon the charge of electronic enticement of a child in the first degree in violation of Haw. Rev. Stat. 707-756. Defendant moved to dismiss counts I and III, arguing that section 707-756 violates the dormant commerce clause and that the statute is unconstitutionally overbroad and vague. The trial court denied the motions to dismiss. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) based upon the plain language of section 707-756, its legislative history, and principles of statutory construction, the felonious intent of the statute applies only to the agreement element of that statute; and (2) the statute is not unconstitutionally overbroad or vague, and its application does not violate the dormant commerce clause. View "State v. Alangcas" on Justia Law