Justia Hawaii Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The City and County of of Honolulu provided refuse collection services through the use of front-end loader work crews to service 181 multi-unit residential properties and numerous City agencies. After the City decided to discontinue front loader collection services, United Public Workers (the Union) sued the City and County. The Union filed a motion for a preliminary injunction seeking to enjoin the City from unilaterally implementing the privatization of the collection and disposal services. The circuit court granted partial summary judgment to the Union and permanently enjoined the City from discontinuing the services at issue, concluding that the City and County’s cancellation of the services constituted impermissible privatization. The circuit court certified the partial summary judgment order for appeal and stayed the proceedings as to the remaining counts. The Supreme Court affirmed, holding (1) the City and County’s decision to terminate front loader refuse collection services violated constitutional merit principles and civil service laws and deprived the civil service workers in this case of the protections guaranteed in Article XVI, Section 1 of the Hawaii Constitution and Haw. Rev. Stat. 76 and 77; and (2) the circuit court did not err in granting partial summary judgment in favor of the Union as to the asserted violations of constitutional merit principles. View "Salera v. Caldwell" on Justia Law

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Defendant was found guilty of operating a vehicle under the influence of an intoxicant (OVUII), in violation of Haw. Rev. Stat. 291E-61(a)(1) and/or (3). The Intermediate Court of Appeals (ICA) affirmed the judgment on appeal. The Supreme Court affirmed, holding (1) the district court did not err in permitting the State to amend Defendant’s section 291E-61(a)(1) charge to allege mens rea; and (2) insofar as the section 291E-61(a)(1) charge was properly amended and insofar as Defendant did not challenge the sufficiency of the evidence supporting his conviction for violating section 291E-61(a)(1), his OVUII conviction still stands, and there is no need to address Defendant’s argument that the breath test result supporting his section 291E-61(a)(3) conviction was obtained in violation of his constitutional rights. View "State v. Fisher " on Justia Law

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After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. The district court denied Defendant’s motion to suppress the breath test results and found Defendant guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Guard " on Justia Law

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After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. The district court denied Defendant’s motion to suppress the breath test results and found Defendant guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Guard " on Justia Law

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After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station, where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant moved to suppress the breath test results, arguing that he did not voluntarily consent to breath testing. The district court denied the motion and convicted Defendant of OVUII. The intermediate court of appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Bayudan " on Justia Law

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After being arrested for OVUII, Defendant was taken to the police station, where he was read an implied consent form. After being informed of the sanctions for refusal, Defendant elected to take a blood test, which resulted in a blood alcohol reading above the legal limit. Defendant was ultimately convicted of OVUII. The Intermediate Court of Appeals upheld the conviction. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s blood test was the product of a warrantless search, and accordingly, Defendant’s conviction could not be upheld. View "State v. Elberson " on Justia Law

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After being arrested for OVUII, Defendant was read an implied consent form. Defendant elected to take a blood test, which resulted in a blood alcohol reading above the legal limit. Defendant filed a motion to suppress the blood test results, arguing that the results were obtained in violation of the Fourth Amendment. The district court denied the motion to suppress, and Defendant was convicted of OVUII. The Supreme Court reversed, holding that, in accordance with State v. Won, the result of Defendant’s blood test was the product of a warrantless search, and accordingly, Defendant’s conviction could not be upheld. View "State v. Reilly " on Justia Law

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After being arrested for operating a vehicle under the influence of an intoxicant (OVUII) Defendant was taken to the police station, where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant filed a motion to suppress the breath test results. The district court denied the motion to suppress. Thereafter, Defendant was convicted of OVUII. The Intermediate Court of Appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, Defendant’s OVUII conviction could not be upheld. Remanded. View "State v. Shigemura " on Justia Law

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After being arrested for operating a vehicle under the influence of an intoxicant (OVUII) Defendant was taken to the police station, where he was read an implied consent form. Defendant subsequently elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant filed a motion to suppress the breath test results. The district court denied Defendant’s motion to suppress, and Defendant was convicted of OVUII. The Intermediate Court of Appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, Defendant’s OVUII conviction could not be upheld. View "State v. Kernstock " on Justia Law

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After being arrested for operating a vehicle under the influence of an intoxicant (OVUII) Defendant was taken to the police station, where he was read an implied consent form. The consent form conveyed a threat of imprisonment and punishment for refusal to submit to a breath test. Defendant subsequently elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant filed motions to suppress evidence of his breath test, arguing that he did not constitutionally consent to the breath test because his consent was coerced by the implied consent form. The district court denied Defendant’s motions to suppress. Defendant was convicted of OVUII. The Intermediate Court of Appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, Defendant’s OVUII conviction could not stand. View "State v. Mikawa " on Justia Law