Justia Hawaii Supreme Court Opinion Summaries

Police officers in Kona, Hawai‘i, stopped a car for expired registration with Charles Zuffante as a passenger and his girlfriend as the driver. During the stop, officers observed a glass pipe and subsequently arrested both individuals. A search of Zuffante revealed 3.5 grams of methamphetamine, and a later search of the car uncovered an additional 130 grams of methamphetamine in various containers. The officers recorded the stop with body-worn cameras. The following day, a detective interrogated Zuffante in the Kona police station, where Zuffante signed a waiver of rights. Although the interrogation room was equipped for video recording, no recording was made due to claimed equipment failure. The detective did not take notes and later wrote a report summarizing Zuffante’s statements.Zuffante moved in limine in the Circuit Court of the Third Circuit to exclude the detective’s testimony about the unrecorded interrogation, arguing that admitting such testimony violated his constitutional rights and urging the court to adopt the recording requirement from Stephan v. State, as rejected in State v. Kekona. The circuit court denied the motion, and at trial, the detective testified that Zuffante confessed to possessing all the methamphetamine. Zuffante testified in his own defense, denying the confession. The jury convicted Zuffante of multiple drug offenses, and he was sentenced to twenty years in prison. On appeal, the Intermediate Court of Appeals (ICA) affirmed the conviction.The Supreme Court of the State of Hawai‘i reviewed the case and held that the Hawai‘i Constitution’s due process clause requires law enforcement to record all in-station custodial interrogations and, when feasible, all outside-the-station custodial interrogations. The court overruled State v. Kekona and established that failure to record, absent a showing of infeasibility, results in exclusion of the unrecorded statement. The court vacated the ICA’s judgment and the circuit court’s conviction, remanding for further proceedings. View "State v. Zuffante" on Justia Law

In 1922, the Territory of Hawai‘i issued a Land Patent for a 3.99-acre property to a trustee for the Church of Jesus Christ of Latter-Day Saints, with a deed restriction requiring the property to be used “for Church purposes only.” If used otherwise, the property would revert to the Territory. Over the years, the property changed hands several times, with each transaction referencing the original deed restriction. The current owners, Hilo Bay Marina, LLC and Keaukaha Ministry LLC, are not religious institutions and sought to have the restriction removed, arguing it was void under Hawai‘i Revised Statutes § 515-6(b), and violated both the Hawai‘i and Federal Establishment Clauses.The Circuit Court of the Third Circuit granted summary judgment for the State of Hawai‘i and its Board of Land and Natural Resources, finding that the deed restriction was a permissible form of early use-zoning, did not violate the cited laws, and was covered by the statutory exemption for religious use. The court also concluded that the restriction did not violate either the Hawai‘i or Federal Establishment Clauses, applying both the Lemon test and the more recent “historical practices and understandings” standard from Kennedy v. Bremerton School District.On appeal, the Supreme Court of the State of Hawai‘i reviewed the case de novo. The court found that the record did not support the lower court’s conclusion that the deed restriction was an early form of use-zoning. It held that the State’s enforcement of the restriction violated the Hawai‘i Establishment Clause, as it required the State to actively police religious use and entangled the government with religious affairs. The court reversed the Circuit Court’s judgment for the State, vacated its ruling on the Federal Establishment Clause, and held that summary judgment should be entered for the plaintiffs. View "Hilo Bay Marina, LLC v. State" on Justia Law

The case concerns a defendant who was indicted for murder and attempted murder following a shooting incident in Kona, Hawaii. The indictment included sentencing enhancements under Hawaii Revised Statutes (HRS) § 706-660.1, which allows for mandatory minimum sentences if a firearm is possessed, used, or its use is threatened during the commission of a felony. The indictment did not specify a state of mind (mens rea) for the sentencing enhancement, though it did for the underlying offenses. At trial, the defendant was convicted on several counts, and the jury found the firearm enhancement applied. The defendant was sentenced accordingly.After the initial conviction, the Intermediate Court of Appeals (ICA) vacated the conviction on certain counts due to evidentiary errors and remanded for a new trial. On remand, the defendant, for the first time, challenged the sufficiency of the indictment, arguing that the sentencing enhancement was an element of the offense and thus required a state of mind to be alleged. The Circuit Court agreed and struck the enhancements from the indictment, finding that the omission of a state of mind violated due process and the requirements set forth in prior case law.The State appealed, and the ICA reversed the Circuit Court’s order, holding that the sentencing enhancement under HRS § 706-660.1 is not an element of the underlying offense and does not require a state of mind to be pled in the indictment. The Hawaii Supreme Court reviewed the case and affirmed the ICA’s decision. The Court held that sentencing enhancements under HRS § 706-660.1 are not elements of the offense and that due process is satisfied if the defendant is notified that the enhancement will be sought and the indictment contains sufficient factual allegations. The Court remanded the case for further proceedings. View "State v. Smith" on Justia Law

A group of plaintiffs from Kauaʻi, Oʻahu, and Maui challenged a series of emergency proclamations issued by the Governor of Hawaiʻi, beginning in July 2023, which declared affordable housing a state emergency. These proclamations suspended various state laws and established expedited processes for approving and constructing housing projects, including the creation of a State Lead Housing Officer and a Build Beyond Barriers Working Group. The initial proclamations allowed all housing projects, not just affordable housing, to benefit from the suspended laws and expedited certification. Over time, the proclamations were revised, narrowing their scope and transferring certification authority to the Hawaiʻi Housing Finance and Development Corporation (HHFDC).The plaintiffs first filed a writ of quo warranto against the State Lead Housing Officer and the Working Group, arguing that the proclamations exceeded the governor’s statutory authority and violated constitutional provisions. The Circuit Court of the Second Circuit dismissed the petition without prejudice, finding the mechanism inapplicable and the claims moot, but allowed amendment. Plaintiffs then filed an amended complaint for declaratory relief against the governor and HHFDC, which was also dismissed for lack of standing and procedural defects. Plaintiffs appealed, and after briefing in the Intermediate Court of Appeals, the case was transferred to the Supreme Court of Hawaiʻi.The Supreme Court of Hawaiʻi held that the case was justiciable, plaintiffs had standing based on their constitutional right to a clean and healthful environment, and procedural missteps did not bar their claims. The court articulated a standard for reviewing emergency proclamations: they must be rationally related to public health, safety, and welfare, and the executive actions must be reasonably necessary to address the emergency. Applying this, the court found the Sixth through Fifteenth proclamations valid, but held the first five exceeded the governor’s emergency powers. The court vacated the circuit court’s dismissal of the declaratory judgment claims. View "Nakoa v. Governor of the State of Hawai'i" on Justia Law

A company had been diverting large amounts of water from streams in East Maui for over twenty years under a series of annually renewed, so-called “temporary” permits issued by the state’s Board of Land and Natural Resources (BLNR). Each year, the company applied to renew these permits, which allowed it to use state land and divert millions of gallons of water daily. In 2020, before BLNR voted to renew the permits for 2021, an environmental group timely requested a contested case hearing, arguing that new evidence and changed circumstances warranted further scrutiny. BLNR denied this request and proceeded to renew the permits, adding some new conditions.The environmental group appealed to the Environmental Court of the First Circuit, challenging both the denial of a contested case hearing and the permit renewals. The Environmental Court found that the group had a constitutionally protected right to a clean and healthful environment, as defined by state law, and that due process required a contested case hearing before the permits were renewed. The court vacated the permits but stayed its order to avoid disruption, temporarily modifying the permits to reduce the allowable water diversion. The court also awarded attorney fees and costs to the group.On appeal, the Intermediate Court of Appeals (ICA) held that the group’s protected interest was defined by some, but not all, relevant environmental laws, and that due process did not require a contested case hearing in this instance. The ICA further found that the Environmental Court lacked jurisdiction over the permit renewals and erred in modifying the permits and awarding attorney fees.The Supreme Court of Hawaiʻi reversed the ICA in relevant part. It held that the group’s constitutional right was defined by all cited environmental laws, including those governing coastal zone management. The court concluded that due process required a contested case hearing before the permits were renewed, and that the Environmental Court had jurisdiction to review both the denial of the hearing and the permit renewals. The Supreme Court also affirmed the Environmental Court’s authority to temporarily modify the permits and to award attorney fees and costs to the environmental group. View "Sierra Club v. Board of Land and Natural Resources" on Justia Law

A defendant, Jerome Rogan, was convicted of sexual assault, but his conviction was reversed by the Supreme Court of Hawai'i due to prosecutorial misconduct, preventing retrial. Alan Ahn, a former police officer, had his charges dismissed after a deferred acceptance of a no contest plea. Both Rogan and Ahn received expungement orders from the Department of the Attorney General and requested the court to seal their records.The Circuit Court of the First Circuit initially handled Ahn's case, where a grand jury indicted him on drug-related charges. After procedural complexities, including a motion to unseal records by Nick Grube, Ahn's charges were eventually dismissed. Rogan's case was straightforward, with his conviction being reversed by the Supreme Court of Hawai'i.The Supreme Court of the State of Hawai'i reviewed the consolidated cases of Rogan and Ahn. The court held that under Hawai'i Revised Statutes (HRS) § 831-3.2(f), judicial records must be removed from the judiciary’s publicly accessible electronic databases (eCourt Kōkua) but remain accessible for in-person review at the courthouse. The court emphasized that the public has a constitutional right to access court records under article I, section 4 of the Hawai'i Constitution, which cannot be overridden by automatic sealing. The court also noted that the judiciary has exclusive control over its records under article VI, section 7 of the Hawai'i Constitution. The court denied the motions to seal the records but granted the removal of the records from eCourt Kōkua. View "State v. Rogan." on Justia Law

This case involves a property on Maui in which Wade Brady owned a 50% interest. Beverly and James Spence obtained a default judgment against Wade and Katherine Brady in 2010, which they recorded as a lien against Wade Brady’s interest in the property. After the Bradys failed to satisfy their debt, the Spences obtained a writ of execution to sell the property. The sale was advertised by publication, and Wade Brady’s interest was sold to the Spences. At the time of the sale, Peter J. Winn and Westminster Realty, Inc. (the Winn parties) also had a recorded junior judgment lien on the property but did not receive personal notice of the sale.The Circuit Court of the Second Circuit confirmed the sale, stating it was free of all junior liens. The Winn parties later sought to execute their judgment on the property, but the circuit court denied their motion, stating they were not entitled to personal notice. The Intermediate Court of Appeals (ICA) vacated the circuit court’s order, holding that the Winn parties had a constitutionally protected property interest and were entitled to personal notice of the sale.The Supreme Court of the State of Hawai‘i reviewed the case. The court held that a recorded judgment lien under HRS § 636-3 creates a constitutionally protected property interest. The court further held that due process requires personal notice to junior judgment lienholders when the executing party knows or should know of their interest. However, the court decided that this ruling would apply prospectively only, due to the potential impact on prior and pending execution sales and the substantial prejudice to the intervenors. The court reversed the ICA’s decision to reinstate the Winn parties’ lien on the property. View "Winn v. Brady" on Justia Law

In the 2024 general election for State Representative, District 39 in Hawaii, the two candidates were Republican Elijah Pierick and Democrat Corey Rosenlee. The election was primarily conducted by mail, with in-person voting available at voter service centers. The City Clerk of Honolulu was responsible for mailing and receiving ballots, while the State Office of Elections handled the counting. After the election, Pierick received 4,712 votes, and Rosenlee received 4,701 votes, with a vote differential of 11 in favor of Pierick. Rosenlee contested the election results, alleging mistakes in the handling of return identification envelopes and long lines at voter service centers.Rosenlee filed an election contest with the Supreme Court of Hawaii on November 25, 2024. He claimed that the Clerk made mistakes in reviewing signatures on return identification envelopes, only mailing notice of deficiencies, and managing in-person voting lines. He also alleged that the Clerk's actions violated equal protection and due process. The defendants filed motions for dismissal or summary judgment, arguing that no mistakes were made and that Rosenlee failed to provide evidence to support his claims.The Supreme Court of Hawaii reviewed the evidence and found that the Clerk followed the proper procedures for validating signatures on return identification envelopes. The court concluded that Rosenlee did not provide sufficient evidence to prove that any mistakes by the Clerk affected the election results. The court also found that the Clerk provided reasonable notice and opportunity for voters to cure deficiencies in their return identification envelopes. As a result, the court ruled in favor of the defendants and confirmed Pierick's election as State Representative, District 39. The court ordered the Chief Election Officer to deliver the certificate of election to Pierick. View "Rosenlee v. Takahashi " on Justia Law

Randall Hoffman was observed by Officer Warren Tavares of the Hawai‘i State Department of Land and Natural Resources dumping green waste from a trailer on a Kaua‘i roadside. After a verbal exchange and a physical altercation, Hoffman was arrested and charged with assault against a law enforcement officer, resisting arrest, and criminal littering. During the encounter, Hoffman made several statements to Officer Tavares without being Mirandized.The Circuit Court of the Fifth Circuit suppressed all of Hoffman's statements, concluding they were made during custodial interrogation without Miranda warnings. The court found that Officer Tavares's statements were likely to elicit incriminating responses from Hoffman. The State appealed, arguing that the statements were made in response to actions and words normally attendant to arrest and custody.The Intermediate Court of Appeals (ICA) affirmed in part and vacated in part the circuit court's order. The ICA agreed that some of Officer Tavares's statements were likely to elicit incriminating responses and upheld the suppression of Hoffman's statement about being turned away from a county refuse station. However, the ICA ruled that other statements by Hoffman, including his expletive responses and his statement during the scuffle, were voluntary utterances not in response to interrogation.The Supreme Court of the State of Hawai‘i reviewed the case and held that under Article I, Section 10 of the Hawai‘i Constitution, the ultimate inquiry is whether a law enforcement officer knew or should have known that their words or conduct were reasonably likely to elicit an incriminating response. The court affirmed the ICA's decision in part, vacated it in part, and remanded the case for further proceedings, holding that some of Hoffman's statements were indeed responses to interrogation and should be suppressed, while others were not. View "State v. Hoffman" on Justia Law

This case involves a challenge to a statute and a constitutional provision in Hawaii that relate to the prosecution of continuous sexual assault of a minor under the age of fourteen. The defendant, Alvin Tran, was charged with violating this statute. After a trial, a jury found him guilty. Tran then filed a motion for a new trial, arguing that the statute and the constitutional provision violated the U.S. Constitution because they did not require the jury to unanimously agree on the specific acts that constituted the continuous sexual assault. The trial court denied this motion. Tran also filed a motion to dismiss the indictment against him, arguing that it was not specific enough. The trial court granted this motion in part and denied it in part, dismissing the case but allowing the state to refile the charges.The Supreme Court of the State of Hawaii held that the statute and the constitutional provision did not violate the U.S. Constitution. The court reasoned that these provisions did not authorize non-unanimous jury verdicts, which would be unconstitutional. Instead, they allowed a unanimous jury to find a defendant guilty even if the jurors did not agree on which specific acts constituted the continuous sexual assault. The court also held that the indictment against Tran was sufficient. Therefore, the court vacated the trial court's order dismissing the case and remanded the case for further proceedings. View "State v. Tran" on Justia Law