Justia Hawaii Supreme Court Opinion Summaries

Petitioner was found guilty of operating a vehicle under the influence of an intoxicant. Petitioner appealed the denial of his motion to suppress the results of a breath alcohol test that he took after he was arrested, arguing that he did not constitutionally consent to the breath test because the implied consent form conveyed a threat of imprisonment and significant punishment for his refusal to submit to the test. The Supreme Court vacated the judgment, holding that the result of Petitioner’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Petitioner’s motion to suppress the breath test result. Remanded. View "State v. Cheek-Enriques " on Justia Law

Petitioner entered a conditional plea to the charges of habitually operating a vehicle under the influence of an intoxicant and of driving while license suspended or revoked. Petitioner subsequently appealed the denial of his motion to suppress evidence of a breath alcohol test that he took after he was arrested. Specifically, Petitioner contended that he did not constitutionally consent to the breath test because his consent was coerced by the implied consent form, which conveyed a threat of imprisonment and significant punishment for his refusal to submit to the test. The intermediate court of appeals affirmed the denial of Petitioner’s motion to suppress. The Supreme Court vacated the lower courts’ judgments, holding that the result of Petitioner’s breath test was the product of a warrantless search because the implied consent form was coercive. Remanded with instructions to enter an order granting Petitioner’s motion to suppress and to allow Petitioner to withdraw his conditional guilty plea as to both charges. View "State v. Lee " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII) Defendant was taken to the police station, where she was read an implied consent form. Defendant chose to take a breath test, which resulted in an elevated breath alcohol content. The district court adjudged Defendant guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that Defendant’s consent was coerced by the implied consent form, which conveyed a threat of imprisonment and significant punishment for refusal to submit to a breath test. Consequently, the result of Defendant’s breath test was the product of a warrantless search, and the district court erred by denying Defendant’s motion to suppress the breath test result. View "State v. Murphy " on Justia Law

The district court adjudged Defendant guilty of operating a vehicle under the influence of an intoxicant (OVUII). The intermediate court of appeals (ICA) affirmed. On certiorari, Defendant argued that he did not constitutionally consent to a breath test that was taken after his arrest for OVUII because his consent was coerced by an implied consent form that conveyed a threat of imprisonment and punishment for refusal to submit to a breath, blood, or urine test. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that the result of Defendant’s breath test was the produced of a warrantless search, and therefore, the motion to suppress should have been granted. Remanded. View "State v. Gladman " on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree. Defendant appealed, arguing that the circuit court erred in (1) denying his post-verdict motion for judgment of acquittal on statute of limitations grounds, and (2) denying his request to instruct the jury on the lesser included offense of sexual assault in the third degree. The intermediate court of appeals (ICA) vacated Defendant’s conviction on the ground that the circuit court erred in failing to instruct the jury on sexual assault in the third degree. Defendant appealed, challenging the ICA’s rejection of his claim that his post-verdict motion for judgment of acquittal should have been granted by the circuit court. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant’s motion for judgment of acquittal; but (2) erred in failing to instruct the jury that the State had to prove beyond a reasonable doubt facts establishing the timeliness of the prosecution, but this error was harmless. View "State v. Abdon" on Justia Law

Defendant was found guilty of operating a vehicle after license and privilege have been suspended of revoked for operating a vehicle under the influence of an intoxicant. The intermediate court of appeals (ICA) affirmed, concluding that the district court did not err in permitting the State to amend the charge against Defendant to allege the required mens rea for the offense. The Supreme Court affirmed, holding (1) the defective charge did not constitute a jurisdictional defect that failed to confer subject-matter jurisdiction to the district court; and (2) Defendant’s remaining claims lacked merit. View "State v. Gomez " on Justia Law

Defendant was arrested for operating a vehicle under the influence of an intoxicant (OVUII). Defendant was subsequently taken to the police station where she read an implied consent form, which conveyed a threat of imprisonment and significant punishment for refusal to submit to a breath, blood, or urine test. Defendant chose to take a breath test. Defendant was later convicted of OVUII. Defendant filed a motion to suppress the breath test result, arguing that she did not constitutionally consent to the breath test because her consent was coerced by the implied consent form. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment and remanded to the district court, holding that, in light of State v. Won, the result of Defendant’s breath test is the product of a warrantless search. View "State v. Tavares " on Justia Law

Defendant was convicted of entering or remaining in a public park during posted closure hours in violation of Honolulu ordinances. Defendant waived the “involvement” of a public defender after consulting with the public defender’s office before trial. The Intermediate Court of Appeals affirmed the conviction. The Supreme Court vacated Defendant’s conviction and remanded the case for a new trial, holding that Defendant’s waiver of his right to counsel was not knowingly and intelligently made, as the district court failed to conduct a formal inquiry regarding Defendant’s waiver of his right to counsel. View "State v. Deming " on Justia Law

After a jury trial, Defendant was found guilty of assault in the third degree. The circuit court sentenced Defendant to thirty days’ imprisonment and increased Defendant’s bail from $200 to $2,000 cash only pending execution of sentence. The Supreme Court vacated the circuit court’s judgment of conviction and sentence, holding (1) the circuit court plainly erred in failing to instruct the jury on mutual affray; and (2) the circuit court abused its discretion in increasing Defendant’s bail from $200 to $2,000 cash only. Because there was sufficient evidence for the conviction, the matter is remanded for further proceedings consistent with this opinion. View "State v. Henley" on Justia Law

Defendant was charged with violation of a protective order. The date of the trial was continued for one month because the trial judge was ill. This continuance resulted in Defendant’s trial not beginning until fourteen days after the six-month period under Haw. R. Penal P. 48 for trying a criminal defendant expired. Defendant filed a motion to dismiss for a violation of his right to a speedy trial. The family court denied the motion, concluding that the continuance due to the judge’s illness extended the Rule 48 trial deadline by one month because the illness constituted “good cause” for delay under Rule 48(c)(8). After a trial, the jury found Defendant guilty. The Intermediate Court of Appeals affirmed the judgment of conviction. The Supreme Court vacated the judgments of the lower courts, holding that, under the circumstances of this case, the family court erred in determining that the trial judge’s illness constituted good cause to exclude one month under Rule 48. Remanded. View "State v. Abregano" on Justia Law