Justia Hawaii Supreme Court Opinion Summaries

The defendant was convicted of second-degree murder following the disappearance of his former girlfriend, who was last seen at his apartment on January 12, 2014. The defendant claimed she left his apartment that night to be picked up by her son, but her son denied this, and she was never seen again. Evidence at trial included testimony about her abrupt disappearance, her close relationships, and her uncharacteristic lack of contact and financial activity after that date. Investigators presented circumstantial evidence, including electronic records showing her phone accessed social media from the defendant’s IP address after the time he claimed she left, and testimony about the defendant’s behavior following her disappearance.The Circuit Court of the Second Circuit initially dismissed a 2019 indictment without prejudice, but a second grand jury indicted the defendant in December 2020. The defendant moved to dismiss the second indictment, arguing insufficient evidence, juror bias, and excessive hearsay, but the circuit court denied the motion, finding probable cause. The court also denied motions to suppress the defendant’s police interview and his subscriber name obtained via subpoena, allowing only his name into evidence. At trial, the jury found the defendant guilty, and post-verdict motions for acquittal or a new trial were denied. The defendant appealed to the Intermediate Court of Appeals, raising multiple points of error, and the case was transferred to the Supreme Court of Hawaiʻi.The Supreme Court of Hawaiʻi affirmed the conviction, holding that there was sufficient evidence to support the verdict, the circuit court did not err in admitting the defendant’s statement to police or his subscriber name, and the claims of prosecutorial misconduct, plain error in jury instructions, defects in the indictment, and pre-indictment delay were not established. The court found no abuse of discretion or reversible error in the lower court’s rulings. View "State v. Brown" on Justia Law

A man was charged in 2003 with second-degree murder in Hawai‘i, facing a possible life sentence without parole due to a sentencing enhancement for especially heinous crimes. After initially pleading not guilty, he changed his plea to no contest in 2004, and the court accepted the plea without the enhancement, sentencing him to life with the possibility of parole. Over the next several years, he filed four postconviction petitions, none of which challenged the validity of his plea. In 2019, the court’s records of his 2004 change of plea hearing, including recordings and stenographer notes, were disposed of according to retention policies.In 2021, after learning that no transcript of his change of plea hearing could be produced, the man filed a fifth postconviction petition under Hawai‘i Rules of Penal Procedure (HRPP) Rule 40, now represented by counsel. He argued for the first time that his plea was not made voluntarily, knowingly, and intelligently. The Circuit Court of the Third Circuit, acting as the Rule 40 Court, held an evidentiary hearing and granted relief, vacating his conviction and ordering him held without bail. The State of Hawai‘i appealed, arguing that Rule 40 was invalid, that the court lacked jurisdiction, and that the man’s claims were waived because they could have been raised earlier.The Supreme Court of the State of Hawai‘i held that Rule 40 is valid under its constitutional rulemaking authority and that the Rule 40 Court had jurisdiction. Although the man appeared to have waived his claim by not raising it in earlier petitions, the Supreme Court found that unusual circumstances and the interests of justice warranted review. On the available record, the Supreme Court concluded that the plea was constitutionally valid. The Court vacated the Rule 40 Court’s judgment and reinstated the original conviction and sentence. View "Eason v. State" on Justia Law

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

A defendant was indicted for two counts involving sexual acts with a minor under fourteen. Before trial, the prosecution filed a bill of particulars specifying the acts alleged to support the charges, including statutory definitions of “sexual contact” and “sexual penetration.” At trial, the minor testified to multiple incidents of sexual contact and penetration over several years, as well as a specific incident in July 2019. The trial court, after acquitting the defendant of the most serious charge, submitted lesser included offenses to the jury and provided jury instructions that used modified statutory definitions, omitting terms not relevant to the evidence. The jury convicted the defendant of Attempted Sexual Assault in the First Degree and Continuous Sexual Assault of a Minor Under Fourteen.The defendant appealed to the Intermediate Court of Appeals, arguing that the jury instructions were erroneous because they allowed conviction for conduct outside the specific acts listed in the bill of particulars. The appellate court agreed, finding that the omission of the bill’s specific acts from the instructions, combined with the broader statutory definitions, may have contributed to the convictions. The appellate court vacated the convictions and remanded for a new trial.The Supreme Court of the State of Hawai‘i reviewed the case. It held that while a bill of particulars limits the evidence the prosecution may present at trial, it does not similarly restrict the content of jury instructions. The court found that the omission of the specific acts from the jury instructions was not erroneous and that there was no reasonable possibility any instructional error contributed to the convictions. The Supreme Court reversed the appellate court’s judgment and affirmed the trial court’s judgment of conviction and sentence. View "State v. Masuda-Mercado" on Justia Law

A defendant was charged with second-degree murder after his elderly, wheelchair-bound landlord was found dead with multiple stab wounds. The prosecution presented extensive physical and circumstantial evidence, including DNA linking the defendant to the crime scene and the victim, as well as testimony about the defendant’s motive related to an eviction order. The defendant testified in his own defense, offering alternative explanations for the physical evidence.During jury selection in the Circuit Court of the Fifth Circuit, a prospective juror made comments in the courthouse hallway expressing a desire to be excused, stating she “already had [her] opinion” and making remarks about the defendant’s appearance and discomfort with the case. The court questioned the prospective juror and three others who overheard the comments. The prospective juror was excused, and the court issued curative instructions to the remaining jury pool. The three other prospective jurors were not empaneled or selected as alternates. The defense moved for a mistrial, arguing the comments tainted the jury, but the motion was denied.On appeal, the Intermediate Court of Appeals vacated the conviction, finding the trial court’s inquiry into the comments insufficient and the curative instructions inadequate. The State sought review.The Supreme Court of the State of Hawai‘i held that the trial court’s investigation into the comments was adequate, its curative instructions were sufficient to cure any potential prejudice, and any prejudice was harmless beyond a reasonable doubt given the overwhelming evidence of guilt. The court concluded there was no abuse of discretion in denying the mistrial motion, reversed the Intermediate Court of Appeals’ judgment, and affirmed the conviction and sentence. View "State v. Grewer" on Justia Law

Police in Hawai‘i County obtained a search warrant to search an individual suspected of narcotics dealing. The suspect was stopped while driving his pickup truck, and officers executed the warrant, finding nothing on his person. After the search, an officer asked for consent to search the truck. Instead of giving a direct answer, the suspect made an incriminating statement indicating contraband was in the vehicle. He was not told he was free to leave or given Miranda warnings before this exchange. The truck was later searched under a separate warrant, and over an ounce of methamphetamine was found. The suspect was charged and, after a jury trial, convicted of Promoting a Dangerous Drug in the First Degree.The Circuit Court of the Third Circuit denied the defendant’s motions to suppress evidence and found his statements voluntary, admitting them at trial. The court also admitted expert testimony regarding the identity and weight of the drugs, over defense objections about the expert’s qualifications. The Intermediate Court of Appeals (ICA) vacated the conviction, holding that the State failed to lay a sufficient foundation for the expert’s qualifications because it did not show the expert was trained according to the manufacturers’ requirements for the testing devices. The ICA affirmed the circuit court on other issues.The Supreme Court of Hawai‘i reviewed the case. It held that the ICA erred in requiring the State to show the expert was trained in accordance with device manufacturers’ requirements. The proper standard is that the State must establish, by a preponderance of the evidence, the expert’s qualifications, use of valid techniques, and that the instruments were in proper working order. The court also held that the brief continued detention after the search was justified by reasonable suspicion, and that the initial incriminating statement was admissible. Any Miranda violation in subsequent questioning was harmless. The Supreme Court reversed the ICA’s judgment and affirmed the conviction. View "State v. Spies" 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 man was charged with invasion of privacy in the first degree after he placed his iPhone on the outside ledge of a bathroom window to record a 15-year-old girl showering inside a house. The indictment alleged that he intentionally or knowingly installed or used a device in a “private place” without the consent of the person entitled to privacy, in violation of Hawai‘i law. Before trial, the defendant moved to dismiss the indictment, arguing that the charge was insufficient because it did not include the statutory definition of “private place,” which he claimed was ambiguous. The circuit court denied the motion, and a jury found him guilty. He was sentenced to probation and appealed to the Intermediate Court of Appeals (ICA).On appeal, the defendant argued that the indictment was deficient for failing to specify what constituted the “private place.” The ICA, in a plurality summary disposition order, agreed that the charge was deficient and ordered the conviction vacated and the indictment dismissed without prejudice. The ICA did not address the defendant’s other points of error. Judges on the ICA differed in their reasoning, with one judge finding the evidence insufficient to support conviction and another finding the indictment provided adequate notice.The Supreme Court of the State of Hawai‘i reviewed the case on certiorari. The court held that “private place” is an attendant circumstance element of the offense, but the statutory definition does not create an additional element requiring inclusion in the indictment. The term “private place” is not generic and is readily understood by persons of common understanding. The court further found that, based on information available to the defendant before his motion to dismiss, he had actual notice of the nature and cause of the accusation. The Supreme Court vacated the ICA’s judgment and remanded the case for consideration of the remaining appellate issues. View "State v. Kaakimaka" on Justia Law

The case concerns a defendant who, after a domestic dispute, shot and killed his partner in the presence of others, including children. He was initially convicted by a jury of murder and several firearms offenses, and sentenced to life imprisonment with the possibility of parole, with additional consecutive sentences for the firearms charges. The defendant appealed, and the Supreme Court of Hawai‘i found errors in the trial, including the improper admission of prior bad acts and a failure to give a merger instruction, and remanded for a new trial. Instead of a retrial, the defendant entered a plea agreement, pleading guilty to manslaughter, use of a firearm in a separate felony, and felon in possession of a firearm. The parties agreed to use the original presentence report, which included mental health evaluations.Before sentencing, the defendant requested over $8,700 in court funds to hire an expert to assess his dangerousness for sentencing and future parole purposes. The Circuit Court of the Second Circuit denied most of the request, authorizing only $1,000, finding the request excessive and unnecessary since the expert had already evaluated the defendant. The court sentenced the defendant to forty years’ imprisonment: twenty years each for manslaughter and use of a firearm (to run consecutively), and ten years for felon in possession (to run concurrently). The defendant appealed, arguing the denial of expert fees and challenging the severity and rationale of his sentence.The Intermediate Court of Appeals affirmed the sentence and declined to address the expert fees issue, finding it unpreserved due to procedural technicalities. The Supreme Court of Hawai‘i held that the defendant had preserved the expert fees issue and addressed it on the merits. The court held that expert fees for indigent defendants are generally not required for regular sentencing, unless extended term sentencing is sought or unique circumstances exist. The court also held that the new forty-year sentence was not “more severe” than the original life sentence with the possibility of parole, adopting an aggregate approach to compare sentences. The court affirmed the circuit court’s judgment and sentence. View "State v. Lavoie" 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