Justia Hawaii Supreme Court Opinion Summaries

Defendant Lloyd Pratt received three citations when he was found residing in a closed area of a state park. Pratt filed a motion to dismiss the charges, asserting as a defense that his activities were constitutionally-protected native Hawaiian practices, and citing State v. Hanapi, which defined the scope in the criminal context of the legal privilege for native Hawaiians to engage in customary or traditional native Hawaiian practices when such practices conflict with State statute or regulations. The district court denied the motion, held trial, and found Pratt guilty on all three charges. The intermediate court of appeals (ICA) affirmed. The Supreme Court granted certiorari to clarify the law surrounding the assertion of native Hawaiian rights as a defense in criminal cases. The Court affirmed, holding (1) the courts below did not err in utilizing a balancing test in this case; (2) in balancing interests, the court must consider the totality of the circumstances; and (3) under the totality of the circumstances test, Pratt's convictions must be affirmed. View "State v. Pratt" on Justia Law

In this case the Supreme Court was presented with the question of whether the political question doctrine barred Hawaiian Homes Commission Act (HHCA) beneficiaries from using the Hawaiian Constitution's "sufficient sums" provision to demand more legislative funding of the Department of Hawaiian Home Lands (DHHL) when that provision provided no guidance as to how quickly homesteads must be developed. The Supreme Court held (1) judicial determination of "sufficient sums" as to the purpose of DHHL's administrative and operating expenses is not barred as a nonjusticiable political question, and the intermediate court of appeals (ICA) did not err in so holding; but (2) the political question bars judicial determination of what would constitute "sufficient sums" for the purposes of (a) development of home, agriculture, farm and ranch lots, (b) home, agriculture, aquaculture, farm and ranch loans, and (c) rehabilitation projects, and the ICA erred in concluding otherwise. View "Nelson v. Hawaiian Homes Comm'n" on Justia Law

Petitioner Michael Tierney was charged with promoting a detrimental drug in the third degree. The trial court determined that Petitioner's fitness to proceed to trial was at issue and ordered a one person panel to examine Petitioner. Petitioner refused to cooperate with the examination. The trial court proceeded to trial without the examiner's opinion and found Petitioner guilty of the charge. The intermediate court of appeals (ICA) affirmed. The Supreme Court reversed, holding (1) when a court orders an examination to determine whether a defendant is fit to proceed to trial pursuant to Haw. Rev. Stat. 704-404(1) and the defendant refuses to cooperate with the examiner, the examiner must produce a report of the examination that expressly states whether such unwillingness of defendant was the result of physical or mental disease, if possible; (2) if it is not possible for the examiner to make that determination, the examiner must expressly state as much; and (3) because the examiner in this case did not state in his report whether Petitioner was fit to proceed or state that it was impossible to make that determination, the district court abused its opinion in proceeding to trial without the examiner's opinion. View "State v. Tierney" on Justia Law

Petitioner Kevin Yamahata was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant (OVUII) in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeal (ICA) affirmed. Yamahata appealed, contending that the ICA gravely erred in holding that mens rea need not be alleged in either a section 291E-61(a)(1) or (a)(3) charge pursuant to State v. Nesmith. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Yamahata's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Yamahata did not challenge the sufficiency of the evidence as to that basis, his conviction still stood. View "State v. Yamashita " on Justia Law

Petitioner Emilio Soria was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1). The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's judgment, holding that pursuant to State v. Nesmith, which states that mens rea must be alleged in a section 291E-61(a)(1) charge in order to provide fair notice of the nature and cause of the accusation, the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge. Therefore, Shinsato's section 291E-61(a)(1) charge was deficient for failing to allege mens rea. Remanded to the district court with instructions to dismiss the complaint without prejudice. View "State v. Soria " on Justia Law

Petitioner Rew Shinsato was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Shinsato's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Shinsato did not challenge the sufficiency of the evidence as to that basis, Shinsato's conviction still stood. View "State v. Shinsato " on Justia Law

Petitioner Alejandro Padilla was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Padilla's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Padilla did not challenge the sufficiency of the evidence as to that basis, Padilla's conviction still stood. View "State v. Padilla " on Justia Law

Petitioner William Daniels was adjudged guilty of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Daniels' section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Daniels did not challenge the sufficiency of the evidence as to that basis, Daniels' conviction still stood. View "State v. Daniels " on Justia Law

Kevin Nesmith and Chris Yamamoto were each charged with operating a vehicle under the influence of an intoxicant (OVUII) pursuant to Haw. Rev. Stat. 291E-61(a)(1) and/or (a)(3). The trial court found Nesmith and Yamamoto guilty as charged. Nesmith and Yamamoto appealed, alleging that the complaints were legally deficient for having failed to allege mens rea. The intermediate court of appeals (ICA) affirmed, holding that mens rea need not be alleged in a complaint charging crimes under sections 291E-6a(a)(1) and/or (a)(3). The Supreme Court consolidated the cases and held (1) pursuant to State v. Wheeler, a charge of OVUII under section 291E-61(a)(1) must allege the requisite mens rea; (2) an OVUII charge under section 291E-61(a)(3) is an absolute liability offense for which mens rea need not be alleged or proven; (3) the ICA erred by relying on general intent cases to hold that mens rea may be inferred from the allegations in a section 291E-61(a)(1) OVUII charge; and (4) the State v. Nesmith majority erred by extending Haw. Rev. Stat. 806-28 to the district courts. View "State v. Yamamoto" on Justia Law

Defendant Pulumata'ala Eli was convicted of attempted manslaughter. Defendant appealed, arguing that the trial court erred by failing to suppress a statement Defendant made to a detective in violation of his rights under Miranda v. Arizona. The Supreme Court vacated the circuit court's judgment of conviction and sentence, holding (1) the police practice of inviting an arrestee to make a statement and to give his or her "side of the story" or similar entreaties in a "pre-interview" before Miranda warnings are given violates the defendant's constitutional right against self-incrimination and right to due process; and (2) under the circumstances of this case, the Mirandized statement offered into evidence at trial resulted from the exploitation of the said pre-interview practice, and the Miranda warnings subsequently given did not remove the taint of such practice. Remanded for a new trial. View "State v. Eli" on Justia Law