Justia Hawaii Supreme Court Opinion Summaries

John Varel, the owner of a 1,000-acre parcel of property, filed a petition for injunction against harassment directed against Defendant. The circuit court granted the petition and entered an injunction order prohibiting Defendant from entering Varel’s “residence, including yard and garage.” When Defendant was discovered dirt biking on the outer limits of Varel’s property, he was charged with violating the injunction order. The district court concluded that Defendant violated the injunction order. Defendant appealed, arguing that the most reasonable construction of the term “yard,” as used in the injunction order, should not encompass the entire 1,000 acres of Varel’s property. The Intermediate Court of appeals affirmed. The Supreme Court reversed, holding (1) the meaning of “residence, including yard” encompasses only the house where Varel lives and the area directly adjacent to it, and therefore, the area of Varel’s property where Defendant was observed was outside the meaning of “residence, including yard”; and (2) accordingly, the conviction in this case was not supported by sufficient evidence and must be reversed. View "State v. Guyton" on Justia Law

After a jury trial, Petitioner was convicted of terroristic threatening in the second degree and kidnapping. The Intermediate Court of Appeals affirmed Petitioner’s conviction and sentence. The Supreme Court reversed, holding that the circuit court erred in (1) instructing the prosecutor to inform the jury during closing arguments that the complaining witness was unavailable because she was dead - a fact not in evidence - and the error was not harmless beyond a reasonable doubt; and (2) admitting the complaining witness’s preliminary hearing testimony at trial in violation of Petitioner’s right to confrontation, and the error was not harmless. Remanded for a new trial. View "State v. Nofoa" on Justia Law

Defendant was indicted in counts I and III upon the charge of electronic enticement of a child in the first degree in violation of Haw. Rev. Stat. 707-756. Defendant moved to dismiss counts I and III, arguing that section 707-756 violates the dormant commerce clause and that the statute is unconstitutionally overbroad and vague. The trial court denied the motions to dismiss. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) based upon the plain language of section 707-756, its legislative history, and principles of statutory construction, the felonious intent of the statute applies only to the agreement element of that statute; and (2) the statute is not unconstitutionally overbroad or vague, and its application does not violate the dormant commerce clause. View "State v. Alangcas" on Justia Law

In 2001, Petitioner was convicted of possession with intent to distribute crystal methamphetamine. Petitioner was released in 2003 and began a radiological technician (radtech) degree program. In 2007, after graduating from the program, Petitioner applied for a vacant radtech position at Hawai’i Health Systems Corporation (HHSC), d/b/a Hilo Medical Center (HMC) (collectively, HHSC/HMC). HHSC/HMC rejected Petitioner’s application because of his prior drug conviction. Petitioner filed suit, alleging violations of Haw. Rev. Stat. 378-2 and Haw. Const. art. I, 5. The circuit court granted summary judgment for HHSC/HMC. The Supreme Court reversed, holding that the circuit court erred in granting summary judgment where HHSC/HMC did not establish the existence of a rational relationship between the radtech possession and Petitioner’s prior drug conviction that would entitle HHSC/HMC to summary judgment. View "Shimose v. Haw. Health Sys. Corp." on Justia Law

After a trial, Defendant was convicted of committing the offense of prostitution. Defendant appealed, contending that there was insufficient evidence to prove the commission of a prostitution offense. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed the judgment on appeal of the ICA and clarified the prior-to-trial advisement required by State v. Lewis, holding (1) the ICA did not err in concluding that the evidence adduced at trial was sufficient to sustain Defendant’s conviction; (2) in order to more fully protect the right not to testify under the Hawaii Constitution, trial courts when informing the defendant of the right not to testify during the pretrial advisement must also advise the defendant that the exercise of this right may not be used by the fact finder to decide the case; and (3) although the court’s prior-to-trial advisement in this case did not inform Defendant that his silence could not be used against him if he did not testify, there was no error premised on the lack of judicial notice. View "State v. Monteil" on Justia Law

Defendant was charged with assault against a law enforcement officer in the second degree, resisting arrest, and disorderly conduct. Before trial, the circuit court denied defense counsel’s motion for withdrawal and substitution of counsel. A jury found Defendant guilty of the three charges. The Intermediate Court of Appeals affirmed, holding that the circuit court did not abuse its discretion in (1) denying Defendant’s motion for withdrawal and substitution of counsel, and (2) failing to sua sponte hold a hearing to determine Defendant’s competence to stand trial. The Supreme Court vacated the judgments of the lower courts, holding that, under the circumstances of this case, the circuit court (1) committed prejudicial error in denying Defendant’s motion for withdrawal and substitution of counsel; and (2) abused its discretion in not ordering a fitness examination. View "State v. Harter" on Justia Law

Defendant was charged with and convicted of the offense of solicitation with animals in Waikiki Special District based on “an exchange of cash immediately following the activity of picture taking” with Defendant’s birds. Defendant appealed, arguing that the State failed to provide sufficient evidence regarding the element of solicitation. The intermediate court of appeals (ICA) affirmed. The Supreme Court reversed, holding (1) an element of the offense of solicitation with animals in Waikiki Special District is the use of a live animal to request or demand money or gifts; and (2) there was insufficient evidence to prove this element of the offense. View "State v. Abel" on Justia Law

During the trial of State v. Deedy and on the fifth day of jury deliberations, the circuit court conducted five separate court proceedings that were not open to the public. The transcripts from the court sessions were subsequently sealed, and a mistrial was declared as a result of a deadlocked jury. Petitioners, the Honolulu Star-Advertiser and Hawaii News Now, filed petitions for writs of prohibition and mandamus seeking to prohibit the circuit court from sealing any portion of the trial transcript and to prohibit the court from closing the courtroom in a similar manner in a re-trial of State v. Deedy and in any other criminal proceeding. On remand, the circuit court unsealed the transcript. The Supreme Court (1) dismissed the writ of prohibition as moot because the circuit court already unsealed the transcript of the closed proceedings; (2) denied the writ of mandamus as unnecessary in light of the directive of this opinion; and (3) adopted procedures that a court is required to follow before denying public access to a transcript of a closed proceeding. View "Oahu Publ’ns, Inc. v. Hon. Karen Ahn" on Justia Law

Appellant, an inmate in custody, filed a petition post-conviction relief under Haw. R. Penal P. 40, alleging that he was incompetent to stand trial, his trial counsel and appellate counsel provided ineffective assistance, and prosecutorial misconduct. The circuit court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that Appellant’s appeal was without merit where Appellant failed to establish a colorable claim that (1) he was incompetent to stand trial; (2) his appellate counsel provided ineffective assistance for failing to appeal the issue of Appellant’s alleged incompetence to stand trial; (3) his trial counsel was ineffective; and (4) the prosecutor committed misconduct that would warrant relief under Rule 40. View "Fanelli v. State " on Justia Law

The State filed a misdemeanor complaint against Defendant charging him with one count of abuse of a family or household member (domestic abuse). The complaint stated that Defendant engaged in the abuse for more than two years “as a continuing course of conduct.” The circuit court dismissed the State’s complaint without prejudice, concluding that domestic abuse cannot be charged on a continuous conduct theory. The intermediate court of appeals (ICA) reversed, determining that, in some cases, domestic abuse may be charged as a continuous offense. The Supreme Court reversed the ICA’s judgment and affirmed the circuit court’s order dismissing the State’s complaint, holding that an alleged two-year period of domestic abuse cannot be charged on a continuing course of conduct theory. View "State v. Decoite" on Justia Law