Justia Hawaii Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the judgment of the intermediate court of appeals and the circuit court's judgment convicting Defendant of assault in the second degree, holding that the prosecutor's misconduct in this case violated Defendant's due process right to a fair trial. Defendant was convicted of assault in the second degree in connection with an incident involving Defendant's wife (CW). The only witnesses to the incident at the time the injury were Defendant and CW. During trial, the prosecutor made at least eight improper statements during closing argument, and the misconduct affected the central issue to Defendant's self-defense claim of whether he acted with the intent to protect himself. The Supreme Court remanded the case, holding that the strength of the evidence in support of self-defense, the protracted nature of the prosecutorial misconduct, and the court's ineffective curative instructions led to the conclusion that the misconduct was not harmless beyond a reasonable doubt. View "State v. Conroy" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the district court's judgment convicting Defendant of operating a vehicle under the influence of an intoxicant (OVUII), holding that the ICA gravely erred as a matter of law in finding that even if the district court erroneously allowed a police officer to opine that Defendant failed standardized field sobriety tests (SFSTs), the error was harmless. Specifically, the Supreme Court held (1) the district court erred by permitting Officer Joshua Wong to express an expert opinion that Defendant "failed" the SFSTs, and the error was not harmless beyond a reasonable doubt; (2) the district court erred in permitting expert opinion testimony that Defendant had a blood alcohol content of 0.08 or above; (3) the district court did not err in permitting expert opinion testimony that Defendant was intoxicated, but, prospectively, police officers may no longer testify, whether in a lay or expert capacity, that a driver appeared "intoxicated"; and (4) Defendant's conviction was supported by substantial evidence. View "State v. Jones" on Justia Law

Posted in: Criminal Law
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In this criminal case, the Supreme Court held prospectively that once the court receives notice pursuant to Haw. Rev. Stat. 407.5(1) that a defendant's penal responsibility is an issue in the case, the circuit court must advise a defendant of the penal-responsibility defense and obtain a knowing waiver of the defense. During the criminal proceedings in this case, two of the three examiners concluded that Defendant lacked penal responsibility. Defendant insisted that he was not mentally ill and that he did not want to assert a defense based on lack of penal responsibility. The circuit court eventually found Defendant was fit to stand trial, and Defendant was found guilty. On appeal, Defendant argued that the circuit court should have either sua sponte instructed the jury about the defense of criminal responsibility or conduct a colloquy to ensure that he knowingly and voluntarily decided not to raise the defense. The Supreme Court affirmed, holding that (1) going forward, courts have a duty to obtain a knowing and voluntary waiver of a penal-responsibility defense; and (2) the trial court followed the rules in place at the time of Defendant's conviction and had no duty to sua sponte instruct the jury on lack of penal responsibility. View "State v. Glenn" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated Defendant's sentence for theft in the second degree by shoplifting, holding that, pursuant to State v. Auld, 361 P.3d 471 (Haw. 2015), Defendant's sentence violated his right to a jury determination as to whether he qualified to be sentenced as a repeat offender pursuant to Haw. Rev. Stat. 706-606.5. The circuit court sentenced Defendant as a repeat offender to a mandatory minimum of five years' incarceration without the possibility of parole. The circuit court, however, did not require a jury to find that Defendant qualified as a repeat offender beyond a reasonable doubt, as required by Auld. The intermediate court of appeals (ICA) affirmed the conviction and sentence. The Supreme Court vacated the ICA's judgment on appeal and the circuit court's sentence and remanded the case for resentencing, holding (1) Defendant was entitled to the protections of Auld; and (2) the State was required to, but did not, prove Defendant's predicate prior convictions to a jury beyond a reasonable doubt prior to imposition of a mandatory minimum sentence as a repeat offender. View "State v. Means" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the judgment of the district court convicting Defendant of operating a vehicle under the influence of an intoxicant (OVUII), holding that the district court abused its discretion in denying Defendant's motion to compel. Specifically, the Supreme Court held (1) as to Defendant's speedy trial challenges, Haw. R. Penal P. 48 requires a "meaningful" commencement of trial, a trial is "meaningfully" commenced when a trial court reasonably commits its resources to the trial, and this holding applies prospectively to events occurring after publication of this decision; (2) the prosecutor in this case was not required to personally review files of the testifying police officers; and (3) the district court abused its discretion in denying Defendant's motion to compel production of a video recording showing Defendant at the police station after her arrest because the video recording was material to Defendant's defense and her request was reasonable. View "State v. Alkire" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that Defendant's privilege against self-incrimination was infringed when the circuit court permitted the jury to view a video of Defendant invoking that privilege. Defendant was charged with attempted murder in the second degree and assault in the first degree as a result of an altercation with another person during which Defendant allegedly punched and kicked that person multiple times. During trial, the State played for the jury a video of a detective interviewing Defendant that concluded with Defendant declining the detective's request that Defendant reenact the altercation. The jury convicted Defendant of attempted murder in the second degree. The ICA affirmed. The Supreme Court remanded the case for a new trial, holding that Defendant invoked his right to remain silent when he declined to participate in a reenactment of the encounter and that his right to do so was infringed when the prosecution played the police interview video before the jury at trial. View "State v. Beaudet-Close" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction of operating a vehicle under the influence of an intoxicant (OVUII), holding that admissibility of evidence under Haw. R. Evid. 608(b) involves a two-step inquiry and that the ICA erred to the extent that it suggested a trial court can consider excluded evidence in reaching judgment. At trial, defense counsel sought to impeach the credibility of one of the State's witnesses under Rule 608(b). Counsel argued that specific instances of conduct evincing the witness's untruthfulness were contained in transcripts from three other proceedings in which he was a witness for the State. The district court refused to allow defense counsel to cross-examine the witness concerning these proceedings. The ICA upheld the evidentiary rulings, noting that the district court was able to review the materials concerning the three proceedings. The Supreme Court remanded this case to the district court, holding (1) the district court erred in precluding defense counsel from cross-examining that witness as to two of the proceedings; and (2) to the extent the ICA suggested that the district court reached its judgment by taking into account evidence it had excluded, such suggestion is wrong. View "State v. Su" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the opinion of the Intermediate Court of Appeals (ICA) vacating the circuit court's order granting Defendant's motion to suppress all evidence seized as a result of the execution of a search warrant, holding that the amount of time afforded to Defendant to respond to police officers' demand for entry was not reasonable. Police officers broke down Defendant's front door at approximately 6:15 a.m. after they knocked, announced their presence, and demanded entry four times within a twenty-five-second period. The officers had no reason to believe that Defendant was fleeing or that any evidence was being destroyed. Defendant, who was charged with drug offenses, filed a motion to suppress, arguing that the execution of the warrant violated Haw. Rev. Stat. 803-37 and Haw. Const. art. I, 7. The circuit court granted the motion to suppress. The ICA vacated their circuit court's order, concluding that Defendant was afforded a reasonable amount of time to respond to the police's demand for entry to serve the search warrant. The Supreme Court disagreed, holding (1) giving an occupant only twenty-five seconds to respond at such an early morning hour was unreasonable; and (2) there were no exigent circumstances that would have justified breaching the door earlier than would have otherwise been reasonable. View "State v. Naeole" on Justia Law

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The Supreme Court vacated the Intermediate Court of Appeals' (ICA) judgment on appeal and the circuit court's amended judgment convicting Defendant of burglary in the first degree, holding that Defendant was denied the right to effective assistance at trial. On appeal, Defendant argued that her trial counsel provided ineffective assistance by failing to adduce critical evidence impeaching the credibility of the State's key witness. The Supreme Court agreed and vacated Defendant's conviction, holding that, when viewed as a whole, the adequacy of counsel's representation was not within the range of competence demanded of counsel in criminal cases. View "State v. Salavea" on Justia Law

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The Supreme Court affirmed Defendant's conviction and sentence for murder in the second degree, holding that third party culpability evidence was erroneously excluded, but the error was harmless beyond a reasonable doubt. On appeal, Defendant asserted (1) the trial court abused its discretion by excluding evidence tending to show that a third party committed the offense; (2) the trial court erred by admitting into evidence a confession letter allegedly written by Defendant because of its late disclosure to the defense; and (3) DNA results showing Defendant's presence at the crime scene were improperly admitted at trial. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admitting the confession letter at trial because the timing of the State's disclosure did not require exclusion; (2) a sufficient foundation to admit the results of the DNA analyses was established to allow their admission into evidence; and (3) evidence of the third party's culpability was improperly excluded, but the exclusion was harmless beyond a reasonable doubt. View "State v. Texeira" on Justia Law

Posted in: Criminal Law