Justia Hawaii Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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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 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 gravity of a crime, by itself, does not establish an exigency empowering law enforcement officers to bypass the warrant requirement and that the State must articulate objective facts showing an immediate law enforcement need for the entry to support a warrantless home intrusion under the exigency exception.The State invoked the exigent circumstances exception to justify a warrantless home entry into Defendant's residence. Defendant was subsequently indicted for attempted murder in the second degree. Defendant moved to suppress the evidence found during the search of his residence, arguing that the police lacked exigent circumstances to enter his residence without a warrant. The trial court granted the motion to suppress. The Supreme Court affirmed, holding that the police entered Defendant's home without exigent circumstances, permission, or a warrant, and therefore, the circuit court properly suppressed the evidence. View "State v. Willis" on Justia Law

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The Supreme Court vacated the final judgment of the circuit court granting the State's motion for summary judgment and dismissing Plaintiffs' complaint seeking a declaratory order that a recently enacted bill was adopted through an unconstitutional process, holding that the bill violated Haw. Const. Art. III, 15.Plaintiffs argued in their complaint that the adoption of a law requiring hurricane shelter space in new public schools violated article III, section 15 because the bill did not receive three readings in each house of the Hawai'i State Legislature before it was passed and signed into law. The circuit court granted summary judgment for the State, concluding that the process for enacting the law complied with the Legislature's adopted rules of procedure. The Supreme Court vacated the judgment below, holding (1) article III, section 15 requires that the three readings begin anew after a non-germane amendment changes the purpose of a bill so that it is no longer related to the original bill as introduced; and (2) the bill at issue violated this requirement. View "League of Women Voters of Honolulu v. State" on Justia Law

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The Supreme Court vacated Defendant's conviction for assault in the first degree and remanded this case to the circuit court, holding that the trial court erred in conditioning the admission of evidence on expert testimony.Defendant killed his cousin, Santhony Albert, but claimed he had acted in self-defense. Defendant was convicted of assault in the first degree, and intermediate court of appeals affirmed. On appeal, Defendant argued that the trial court erred in preventing him from advancing evidence of Albert's blood alcohol concentration (BAC) level unless he called an expert to explain its meaning. The Supreme Court agreed, holding that the trial court erred in conditioning the BAC evidence on expert testimony and violated Defendant's constitutional right to present any and all competent evidence to support his defense. View "State v. David" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the circuit court's order denying Defendant's motion for a new trial, holding that the cumulative impact of misconduct on the part of the prosecutor deprived Defendant of a fair trial and was not harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) at trial, the prosecutor introduced to the jury incriminatory statements allegedly made by Defendant without previously disclosing them to the defense during discovery in violation of Haw. R. Pen. P. 16(b)(1); (2) the prosecutor introduced statements that were incriminating to Defendant that were allegedly made by the complaining witness despite the court's motion in limine ruling barring their introduction; (3) the prosecutor engaged in improper and unnecessarily lurid questioning of defense witnesses to inflame the jury's passions; and (4) the circuit court erred in denying Defendant's motion for a new trial based on prosecutorial misconduct, and the ICA erred in concluding that the prosecutor's misconduct was harmless. View "State v. Williams" on Justia Law

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The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) vacating the circuit court's order granting Defendant's motion to suppress evidence obtained in a search of Defendant's bedroom, holding that the circuit court erred in suppressing all evidence obtained by the State.In granting Defendant's motion to suppress, the circuit court determined that Defendant possessed a reasonable expectation of privacy in his bedroom and that the police officer coerced Defendant into opening his bedroom door. The court then suppressed all statements, evidence, observations and actions that were obtained after entry into the bedroom. The ICA vacated the circuit court's order, holding that an emergency aid exception justified the warrantless search. The Supreme Court affirmed on different grounds, holding that, even if the officers unlawfully searched Defendant's bedroom, the evidence obtained did not constitute suppressible "fruit of the poisonous tree." View "State v. Lee" on Justia Law