Justia Hawaii Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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On Defendant's appeal from his convictions of driving without a license and of no motor vehicle insurance, the Supreme Court vacated the judgment of the district court and the intermediate court of appeals (ICA) and remanded this case to the district court for further proceedings, holding that there was no knowing and intelligent waiver of Defendant's fundamental right to a jury trial. Specifically, the Court held (1) the State proved beyond a reasonable doubt that Defendant was not in constructive possession of a license from Mexico or Canada, which would have exempted him from licensing requirements pursuant to Haw. Rev. Stat. 286-105; (2) the ICA erred by requiring Defendant to present evidence of a "borrower/lender relationship" with the registered owner of the vehicle to assert the "good faith lack of knowledge" defense, but this error did not require vacating Defendant's no motor vehicle insurance conviction; but (3) there was no valid waiver of Defendant's right to a jury trial on the charge of driving without a license, and therefore, Defendant's convictions must be vacated and the matter remanded for further proceedings. View "State v. Domut" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the circuit court's judgment of conviction and sentence, holding that the circuit court abused its discretion in denying Defendant's challenge for cause of Juror 48, an error that required that Defendant's conviction be vacated, but that double jeopardy did not preclude a retrial. Defendant was convicted of two counts of theft and one count of criminal property damage. On appeal, Defendant argued, among other things, that the circuit court erred by denying his challenge to two prospective jurors for cause, thereby violating his right to peremptory challenges. The ICA affirmed. The Supreme Court held that Defendant's conviction must be vacated and the case remanded for a new trial because the circuit court improperly denied Defendant's challenge for cause of Juror 48, which required him to exercise one of his peremptory challenges to excuse that juror and caused him to exhaust his peremptory challenge, which impaired his right to exercise a peremptory challenge on a different juror. But because there was substantial evidence to support Defendant's convictions, double jeopardy principles did not preclude a retrial. View "State v. Carroll" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated Defendant's conviction on the charge of assault in the third degree, holding that the deputy prosecuting attorney's elicitation of evidence regarding Child Welfare Services' involvement in violation of a defense motion in limine was improper and not harmless beyond a reasonable doubt. Defendant was charged with assault in the second degree against his minor son. A jury found Defendant guilty of the lesser included offense of assault in the third degree. On appeal, Defendant argued that the family court plainly erred by failing to strike certain improper opening statements made by the deputy prosecuting attorney and by admitting certain x-rays into evidence without the necessary foundation. The intermediate court of appeals affirmed. The Supreme Court set aside the conviction, holding (1) the prosecutor improperly elicited evidence, and the error affected Defendant's substantial rights and was not harmless beyond a reasonable doubt; (2) there was insufficient foundation for admission of the contested x-rays into evidence; and (3) the conviction of assault in the third degree was supported by substantial evidence. View "State v. Williams" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated Defendant's conviction of kidnapping, holding that the circuit court erred in failing to instruct the jury that the "restraint" required to support a kidnapping conviction under Haw. Rev. Stat. 707-720(1)(d) is restraint in excess of any restraint incidental to the infliction or intended infliction of bodily injury or subjection or intended subjection of a person to a sexual offense. Defendant was charged with one count of kidnapping and one count of third degree assault in connection with a single incident. The third degree assault count was dismissed before trial, and, after a trial, Defendant was found guilty on the kidnapping count. The Supreme Court reversed the conviction, holding that the circuit court plainly erred in not instructing the jury that Defendant's restraint of the complaining witness had to be restraint in excess of restraint incidental to any intended infliction of bodily injury or a sexual offense upon the complaining witness. View "State v. Sheffield" on Justia Law

Posted in: Criminal Law
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The Supreme Court overruled State v. Hamili, 952 P.2d 390 (1998), which held that prohibited fishing with gill nets was a nonprobationable offense, holding that the underlying offenses at issue in this case were probationable, and therefore, Hamili is overruled. Defendant entered into a plea agreement whereby he agreed to plead guilty or no contest to hunting hours (count III) and artificial light prohibited (count IV), both petty misdemeanors. Defendant filed a motion for a deferred acceptance of no contest (DANC) plea requesting that the circuit court defer acceptance of his no contest pleas pursuant to Haw. Rev. Stat. Chapter 853. The circuit court denied Defendant's motion for a DANC plea. Defendant was subsequently convicted of count III and count IV. The intermediate court of appeals affirmed, concluding that Defendant was ineligible for a DANC plea under Haw. Rev. Stat. 853-4(a)(5) because the offenses to which he pled no contest were nonprobationable. The Supreme Court vacated the ICA's judgment on appeal and Defendant's conviction and sentence, holding that the district court erred in denying Defendant's motion for a DANC plea. View "State v. Medeiros" on Justia Law

Posted in: Criminal Law
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At issue was whether Defendant could be convicted of homicide if the victim's death was the immediate result of the victim's family's choice to withdraw medical care. The Supreme Court vacated Defendant's conviction of manslaughter and remanded the case for a new trial, holding that the circuit court committed plain error by failing to instruct the jury on causation and culpability pursuant to Haw. Rev. Stat. 702-215 and 207-216. After Defendant severely beat the victim, the victim was comatose for more than a week. Twelve days later, the victim was removed from life support and declared dead. A jury found Defendant guilty of manslaughter. The Supreme Court reversed, holding (1) Haw. Rev. Stat. 327E-13(b), a provision in the Uniform Health-Care Decisions Act, which prohibits designated as a homicide any "[d]eath resulting from the withholding or withdrawal of health care" under the Act, did not shield Defendant from conviction; and (2) the jury should have been given instructions on causation pursuant to sections 702-215 and 702-216, which would have enabled the jury to consider whether the intervening volitional conduct of the medical team and family interrupted the chain of causation between Defendant's actions and the victim's death such that it would be unjust to convict Defendant of homicide. View "State v. Abella" on Justia Law

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The Supreme Court vacated Defendant's conviction of attempted murder in the second degree arising from the stabbing of Defendant's friend, holding that the jury's discovery of "stains" during an improper examination of Defendant's clothing to search for evidence of blood during deliberations was not harmless beyond a reasonable doubt. During deliberations, the jurors requested scissors to cut open the packaging containing Defendant's clothing, and three of the jurors examined the clothing for blood. The jurors found small spots on the inside of the pants and determined that the spots must be blood. The stains had not been introduced as evidence during trial. The Supreme Court vacated Defendant's conviction, holding that the jurors' discovery of the stains constituted an outside influence that may have tainted the jury's impartiality, and the jury's exposure to the stains was not harmless beyond a reasonable doubt. View "State v. Pitts" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction and sentence, holding that the deputy prosecuting attorney (DPA) improperly referenced a pathologist's testimony as a defense expert in two of the most well-publicized murder trials in Hawai'i within the last decade, which affected Defendant's substantial right to a fair trial. Defendant was convicted of manslaughter and sentenced to twenty years of incarceration. On appeal, Defendant challenged the DPA's cross-examination of James Navin, N.D., who had testified in the murder trials involving Kirk Lankford and Matthew Higa, and closing arguments about that testimony. The ICA affirmed. The Supreme Court vacated the ICA's judgment on appeal and remanded the case for further proceedings, holding that the DPA committed misconduct in referencing Navin's testimony, and the error deprived Defendant of her right to a fair trial. View "State v. Udo" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) reversing the judgment of the circuit court granting Defendant's motion to suppress evidence gathered from a search of Defendant's residence, holding that the ICA erred in not accepting the circuit court's findings of fact and in concluding that the particularity requirement was satisfied. As the basis for his motion to suppress Defendant argued that the search warrant did not state with specificity the subunit of the multiple-occupancy building he resided in. The circuit court concluded that the search warrant did not describe Defendant's subunit with particularity and that the search violated Defendant's constitutional rights. The ICA reversed, holding that there residence was not a multiple-occupancy building. The Supreme Court reversed, holding (1) the warrant was invalid because it did not particularly describe Defendant's unit; and (2) the search violated Defendant's constitutional rights. View "State v. Rodrigues" on Justia Law

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The Supreme Court vacated the judgment on appeal of the intermediate court of appeals (ICA) to the extent that it affirmed the circuit court's order of resentencing and revocation of probation, holding that the ICA gravely erred in affirming the order of resentencing and revocation of probation. Defendant pled guilty to two counts of sexual assault in the second degree. The circuit court sentenced Defendant to probation. Defendant later left Hawai'i to visit his father while in Louisiana. In Louisiana, Defendant was arrested for an outstanding warrant from a previous sexual assault in Arkansas. After Defendant failed to report to his probation officer the State filed a motion for revocation of probation. The circuit court found that Defendant inexcusably violated a substantial condition of probation by failing to report to his probation officer and resentenced Defendant. The ICA affirmed. The Supreme Court vacated the judgment, holding that the circuit court abused its discretion in using Defendant's argument that he did not inexcusably violate the terms of his probation as a basis for imposing a harsher sentence in contravention of the rule adopted by the Supreme Court in Stat v. Kamano, 82 P.3d 401 (2003). View "State v. Fleetwood " on Justia Law

Posted in: Criminal Law