Justia Hawaii Supreme Court Opinion Summaries

This case involves John Sing, who was charged with Robbery in the Second Degree and convicted of Attempted Robbery in the Second Degree. Sing and Abraham Sionesini approached Wesley Mau in a park. Sionesini demanded Mau's watch and tugged on it, but Mau pulled his arm away. Sing then lightly punched Mau and both men left the scene. Sing was later indicted for Robbery in the Second Degree under Hawai‘i Revised Statutes (HRS) § 708-841(1)(a) (2014). At trial, the jury did not convict Sing of Robbery in the Second Degree, but convicted him of Attempted Robbery in the Second Degree.Sing appealed his conviction to the Intermediate Court of Appeals (ICA), arguing that the circuit court erred in instructing the jury on Attempted Robbery in the Second Degree and that there was insufficient evidence to support his conviction. The ICA affirmed his conviction, concluding that there was a rational basis for the Attempted Robbery instruction and sufficient evidence to support his conviction.The Supreme Court of the State of Hawai‘i held that Attempted Robbery in the Second Degree is a crime in Hawai‘i, but not under the facts presented in this case. The court found that the circuit court erred by instructing the jury on Attempted Robbery in the Second Degree. The court vacated the ICA’s judgment, the circuit court’s judgment, conviction, and sentence on Attempted Robbery in the Second Degree, and remanded to the circuit court with instructions to dismiss the charges against Sing with prejudice. View "State v. Sing" on Justia Law

The case revolves around a defendant, Melissa Fay, who was prosecuted for driving under the influence and other related charges. She entered a plea agreement, which did not include imprisonment or probation, but agreed to pay a freestanding order of restitution. The District Court of the Second Circuit followed the plea deal and ordered indefinite compliance hearings to monitor Fay's restitution payments. Fay protested, arguing that Hawai'i's restitution enforcement statute, Hawai'i Revised Statutes (HRS) § 706-644, limits the court's authority.Fay's appeal was unsuccessful in the Intermediate Court of Appeals, which agreed with the district court's decision. The Intermediate Court of Appeals held that an independent order of restitution empowers a criminal court to retain jurisdiction over a person who owes restitution. The court ruled that setting recurrent proof of compliance hearings fell within a court's general power to enforce its orders.The Supreme Court of the State of Hawai'i, however, concluded that the district court exceeded its statutory authority. The Supreme Court held that HRS § 706-644, the specific law relating to restitution enforcement, controls over the court's general powers to enforce judgments. The court ruled that a compliance hearing regarding restitution payments can only be ordered if a defendant is on probation or the defendant "defaults" on payment per HRS § 706-644(1). The Supreme Court vacated the Intermediate Court of Appeals' judgment on appeal. View "State v. Fay" on Justia Law

The case involves Zeth Browder, who was charged with first-degree sexual assault, third-degree sexual assault, first-degree burglary, kidnapping, and evidence tampering. The charges stemmed from an incident where Browder allegedly sexually assaulted an elderly woman while she was camping in a county park. The jury found Browder guilty of all charges.The Intermediate Court of Appeals (ICA) reviewed the case and vacated Browder's conviction, ordering a new trial based on inappropriate comments made by the prosecutor during closing arguments. However, the ICA was divided on whether the prosecutor's comment that the witness' testimony was "consistent with someone who's been traumatized" constituted prosecutorial misconduct. The majority held that the statement was not misconduct, while Judge Leonard disagreed, arguing that the remark mirrored one that the Supreme Court of the State of Hawai'i found improper in a previous case, State v. Hirata.The Supreme Court of the State of Hawai'i disagreed with the ICA's majority, holding that the prosecutor's comment was indeed prosecutorial misconduct. The court found that the prosecutor expressed a personal belief about the witness' credibility and introduced new evidence during closing arguments, thereby undermining Browder's right to a fair trial. The court noted that the prosecutor's comment suggested that the witness had been traumatized, a conclusion that was not supported by any expert testimony. The court vacated the part of the ICA's opinion that allowed the prosecutor's comment and remanded the case to the Circuit Court of the Third Circuit. View "State v. Browder" on Justia Law

This case involves a challenge to a statute and a constitutional provision in Hawaii that relate to the prosecution of continuous sexual assault of a minor under the age of fourteen. The defendant, Alvin Tran, was charged with violating this statute. After a trial, a jury found him guilty. Tran then filed a motion for a new trial, arguing that the statute and the constitutional provision violated the U.S. Constitution because they did not require the jury to unanimously agree on the specific acts that constituted the continuous sexual assault. The trial court denied this motion. Tran also filed a motion to dismiss the indictment against him, arguing that it was not specific enough. The trial court granted this motion in part and denied it in part, dismissing the case but allowing the state to refile the charges.The Supreme Court of the State of Hawaii held that the statute and the constitutional provision did not violate the U.S. Constitution. The court reasoned that these provisions did not authorize non-unanimous jury verdicts, which would be unconstitutional. Instead, they allowed a unanimous jury to find a defendant guilty even if the jurors did not agree on which specific acts constituted the continuous sexual assault. The court also held that the indictment against Tran was sufficient. Therefore, the court vacated the trial court's order dismissing the case and remanded the case for further proceedings. View "State v. Tran" on Justia Law

Christopher Wilson was charged with offenses related to carrying a firearm and ammunition in public without the appropriate license in Hawaii. In response, Wilson challenged the constitutionality of the relevant Hawaii Revised Statutes (HRS) § 134-25 (2011) (pistol or revolver) and § 134-27 (2011) (ammunition), arguing that these laws violated his rights under the Second Amendment of the U.S. Constitution and its equivalent in the Hawaii constitution, article I, section 17. The Circuit Court of the Second Circuit dismissed the charges, agreeing with Wilson's argument. The State appealed the dismissal.The Supreme Court of the State of Hawaii concluded that Wilson was only entitled to challenge the constitutionality of the laws he was charged with violating. As such, Wilson could challenge HRS § 134-25 and § 134-27, but not HRS § 134-9, which pertains to licenses to carry firearms and which Wilson had not attempted to comply with.The court found that the text, purpose, and historical tradition of the Hawaii Constitution do not support an individual right to carry firearms in public. The court reasoned that the language of article I, section 17, which mirrors the Second Amendment, ties the right to bear arms to the context of a well-regulated militia. It does not extend this right to non-militia purposes. The court also considered Hawaii's history of strict weapons regulation and the intent of Hawaii's framers.Based on these considerations, the court held that HRS § 134-25 and § 134-27 do not violate Wilson's right to keep and bear arms under article I, section 17 of the Hawaii Constitution and the Second Amendment to the U.S. Constitution. The court vacated the lower court's dismissal order and remanded the case back to the Circuit Court of the Second Circuit. View "State v. Wilson" on Justia Law

In a case before the Supreme Court of the State of Hawai'i, the court ruled on the suppression of text message evidence in a sexual assault prosecution. The defendant, Dylan River James, allegedly admitted to the sexual assault during a text conversation with the alleged victim, who was directed by the police to contact him. The lower court suppressed these text messages, agreeing with James' argument that his rights to self-incrimination and counsel were violated. The lower court reasoned that the alleged victim was acting as a government agent, and thus, James should have been given Miranda warnings.The Supreme Court of the State of Hawai'i vacated the lower courts' decisions. The court ruled that James was not in custody at the time of the text exchange, and thus, Miranda warnings were not required under either the federal or state constitutions. The court also ruled that James' right to counsel had not yet been attached, as adversarial judicial criminal proceedings had not yet been initiated.The court further held that the Intermediate Court of Appeals (ICA) made an error in concluding that it did not have appellate jurisdiction over the lower court's order denying the State's motion for reconsideration. The Supreme Court stated that the State's right to appeal from an order granting a defendant’s motion to suppress includes a right to appeal from a related order denying the State’s motion for reconsideration. The case has been remanded to the lower court for further proceedings. View "State v. James" on Justia Law

In a case before the Supreme Court of Hawaii, the defendant, Kumulipo Iwa Coyote Sylva, was charged with second-degree murder for killing Eduardo Alejandro Cerezo. Sylva admitted to the killing but asserted the affirmative defense of insanity. In a jury trial, three medical examiners testified regarding Sylva's mental state at the time of the killing. Two of the examiners opined that Sylva lacked capacity due to a mental disease, disorder, or defect, thus excluding criminal responsibility. However, parts of the testimony of one of these examiners were struck by the circuit court. Sylva was ultimately convicted of manslaughter based on extreme mental or emotional disturbance (EMED).The Supreme Court of Hawaii held that the circuit court erroneously struck parts of the examiner's testimony which should have been admitted to clarify his opinion under Hawai‘i Revised Statutes § 704-410(4). The court found that a reasonable juror could have believed the circuit court instructed them to disregard the examiner's entire answer explaining his opinion that Sylva lacked capacity under the legal standard for insanity. The error was not harmless beyond a reasonable doubt because Sylva's insanity defense turned largely on the medical examiners’ testimonies. Therefore, the court vacated the circuit court’s judgment, conviction, and sentence, as well as the Intermediate Court of Appeal’s judgment on appeal, and remanded the case to the circuit court for further proceedings. View "State v. Silva " on Justia Law

The Supreme Court of the State of Hawai'i affirmed the judgment of the Intermediate Court of Appeals upholding the conviction of Michael Pickell for operating a vehicle under the influence of an intoxicant. The case centered around the legality of a traffic stop initiated by a Maui County police officer who observed Pickell executing a U-turn at a highway intersection with left turn only markings and signage but no signage explicitly prohibiting U-turns. Pickell argued that in the absence of an express sign prohibiting U-turns, as required by Hawai'i Revised Statutes (HRS) § 291C-82(c), the officer lacked reasonable suspicion to make the traffic stop. The court held that the Maui County ordinance, which requires drivers to follow the directional movements exhibited on markings and signage at intersections, was neither preempted by HRS § 291C-82(c) nor in conflict with it. Therefore, the officer had reasonable suspicion to initiate the traffic stop based on a violation of the Maui County ordinance, and the motion to suppress evidence from the stop was properly denied. View "State v. Pickell" on Justia Law

The Supreme Court vacated the circuit court's judgment, conviction, and sentence related to sentencing in this case, holding that the circuit court erred by not articulating a clear and comprehensive rationale for each of Defendant's consecutive sentences.Pursuant to a plea agreement, Defendant pled no contest to three felony counts. The court sentenced Defendant to consecutive five-year terms on each count for a total of fifteen years. The intermediate court of appeals (ICA) affirmed, thus rejecting Defendant's jurisdictional and sentencing challenges. The Supreme Court vacated the ICA's judgment on appeal and the circuit court's judgment related to sentencing and otherwise affirmed, holding (1) if the State files a complaint in district court and that court lawfully commits the case to circuit court then the circuit court has jurisdiction; and (2) the circuit court did not provide adequate independent grounds to impose each consecutive sentence. View "State v. Bautista" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Defendant for promoting prostitution in violation of Haw. Rev. Stat. 712-1203(1), holding that a reasonable juror could not have concluded that Defendant profited from prostitution within the meaning of Haw. Rev. Stat. 712-1201.After a jury trial, Defendant was found guilty of promoting prostitution. Defendant filed a motion for judgment of acquittal or, in the alternative, motion for new trial, which the circuit court denied. The intermediate court of appeals affirmed, rejecting Defendant's argument that she could not have profited from prostitution under the facts of this case. The Supreme Court reversed, holding that the State failed to prove that Defendant "profit[ed] from prostitution" within the meaning of section 712-1201(2). View "State v. Ibarra" on Justia Law