Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court dismissing without prejudice the complaints in Appellees' cases, holding that the complaints did not have to comply with Haw. Rev. Stat. 805-1, and the State properly initiated the criminal proceedings against Appellees.The State charged Appellees by complaint with operating a vehicle under the influence of an intoxicant (OVUII). Appellees each filed a motion to dismiss for defective complaint and improper arraignment, arguing that the complaint was not supported by the complainant's signature or a declaration submitted in lieu of affidavit. The district court granted the motions to dismiss and dismissed the cases without prejudice. The State appealed, arguing that the district court erred in concluding that the subject charging instruments were required to comply with section 805-1. The Supreme Court agreed and reversed, holding (1) section 805-1 applies only to complaints for a penal summons or an arrest warrant; and (2) the district court erred in dismissing the complaints charging Appellees with OVUII. View "State v. Mortensen-Young" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) determining that Hawai'i law did not require the joinder of Defendant's traffic offenses with his assault offense, holding that the ICA did not err.Defendant was charged with two separate sets of offenses - traffic offenses and an assault offense - that he argued arose from a single criminal episode. Defendant filed a motion to dismiss, arguing that Haw. Rev. Stat. 701-109 required the State to try the traffic offenses and the assault offense together. The circuit court granted the motion to dismiss. The ICA vacated the circuit court's order, holding that the traffic offenses and the assault offense were not so closely related in time, place, or circumstances that section 701-109(2) compelled the joinder of the two proceedings. The Supreme Court affirmed, holding that Hawai'i law did not require joinder under the circumstances. View "State v. Sardinha" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of murder in the second degree and the imposition of two consecutive life sentences without the possibility of parole, holding that Defendant was not entitled to relief on his allegations of error.Answering special verdict forms, the jury found that Defendant committed one of the two murders as a principal and accomplice and the other murder as an accomplice. During sentencing, the trial court enhanced each of Defendant's prison terms beyond the ordinary statutory maximum and ran those sentences consecutively. The Supreme Court affirmed, holding (1) the jury's verdict was not irreconcilably inconsistent; and (2) the trial court did not unlawfully enhance Defendant's two second-degree murder prison terms. View "State v. Perry" on Justia Law

The Supreme Court reversed the decisions of the lower courts affirming the ruling of the Honolulu Police Commission that Louis Kealoha, Chief of Police for the Honolulu Police Department (HPD), was entitled to a defense attorney provided by the City and County of Honolulu to defend him against federal criminal charges, holding that Kealoha did not meet his burden of establishing entitlement to representation.The Commission concluded that four acts alleged in the first superseding indictment against Kealoha entitled Kealoha to representation because they were done in the performance of Kealoha's duty as a police officer, even if the acts were unlawful and regardless of motive. The circuit court and intermediate court of appeals affirmed. The Supreme Court reversed, holding that because nothing in the record indicated that Kealoha was acting to perform his duties as Chief of Police during the conduct at issue, he was not entitled to taxpayer-funded representation. View "City & County of Honolulu v. Honolulu Police Comm'n" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court granting the motion for summary judgment filed by the Hawai'i Criminal Justice Data Center (HCJDC) and dismissing Phillip Barker's action seeking to require the HCJDC to expunge his arrest record, holding that the ICA gravely erred.Barker, who was convicted of disorderly conduct as a violation, applied for expungement of his arrest, asserting that because Haw. Rev. Stat. 701-107(7) provides that a violation does not constitute a crime, he was entitled to expungement pursuant to Haw. Rev. Stat. 831-3.2. The HCJDC denied the application, concluding that Barker had been convicted of a "crime" within the meaning of section 831-3.2(a). The circuit court denied Barker's request for an order requiring the HCJDC to expunge his arrest record. The ICA affirmed. The Supreme Court vacated the judgments below, holding that under the plain language of Haw. Rev. Stat. 701-107(7) and §§ 831-3.2(a), a person arrested for or charged with a crime, including a petty misdemeanor, but convicted of a violation is eligible for expungement because a “violation” is not a “crime.” View "Barker v. Young" on Justia Law

The Supreme Court reversed the order of the circuit court dismissing the second "Felony Information and Non-Felony Complaint" brought by the State recharging Defendant after the circuit court dismissed the charging document as insufficient, holding that, under the facts of this case, the circuit court erred.Defendant was charged with several crimes arising from a hit and run. Defendant moved to dismiss the charges on the grounds that the charging language was fatally insufficient. The circuit court granted the motion, and the State appealed. Thereafter, the State recharged Defendant, attempting to correct the inadequacies identified in the first charging document. The circuit court dismissed, for lack of jurisdiction, the second charging document while the first charging document remained pending on appeal. The Supreme Court reversed, holding that Defendant's filing of the notice of appeal in the first case did not strip the circuit court of jurisdiction over the second case. View "State v. Michaeledes" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for four counts, including murder in the second degree, holding that, under the circumstances of this case, there was no need for a "determination of death" within the meaning of Haw. Rev. Stat. 327C-1.Section 327C-1 defines the process for making "death determinations in the State" in all "civil and criminal actions." During Defendant's criminal trial, the medical examiner who performed the victim's autopsy testified that the cause of the victim's death was a gunshot wound to the head. Nine days after the verdict was rendered, Defendant filed a motion for arrest of judgment and dismissal, arguing that the circuit court lacked jurisdiction over his case because the State failed to show at the grant jury proceeding that the victim had been determined to be brain dead. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the State was not required to met the requirements of section 327C-1 to prove the victim's death; and (2) Defendant's remaining arguments on appeal lacked merit. View "State v. Moon" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court denying Defendant's motion to dismiss the counts against him, holding that Defendant was not entitled to relief on his allegations of error.Defendant was indicted for leaving the scene of an accident involving death or serious bodily injury (count one) and negligent homicide in the second degree (count two). After a trial, the jury found Defendant guilty on both counts. Before sentencing, Defendant moved to dismiss count one and count two, arguing that both counts were defective. The circuit court denied the motion to dismiss, and the ICA affirmed. The Supreme Court affirmed, holding that Defendant did not show that the State's indictment violated his right to know the nature and cause of the accusations against him. View "State v. Blyenburg" on Justia Law

The Supreme Court ruled that the intermediate court of appeals (ICA) had jurisdiction to review the merits of Appellant's postconviction appeal even though the appeal was not properly taken from a final order, holding that the appeal's procedural defects stemmed from ineffective assistance of counsel.Appellant pled no contest to murder in the second degree and was sentenced to life in prison with the possibility of parole. The ICA dismissed Appellant's appeal for lack of appellate jurisdiction because the appeal had not been taken from a final order. The Supreme Court vacated the ICA's decision, holding (1) the order appealed from was not final, and the appeal did not give rise to appellate jurisdiction; and (2) this Court presumes prejudice to Appellant from his counsel's failure to take the procedural steps necessary to make the appeal that Appellant desired, and the appropriate remedy is consideration of the appeal on its merits. View "Suitt v. State" on Justia Law

In this petition for an extraordinary writ the Supreme Court held that when probable cause has been found after a preliminary hearing but the case is dismissed without prejudice due to a defect in the prosecution, Haw. R. Pen. P. 12(g) permits a court to hold a defendant in custody or continue bail for a specified time that is reasonable under the circumstances.After the court dismissed charges against Scott Deangelo, it ordered under Rule 12(g) that Deangelo remain in custody for ninety days while the State sought a grand jury indictment. Deangelo brought this challenge to Rule 12(g), arguing that it violates the Fourth Amendment to the United States Constitution and Haw. Rev. Stat. 803-9(5), which requires an arrested person to be taken before a qualified magistrate for examination within forty-eight hours of arrest. The Supreme Court held that Rule 12(g) is constitutional and that the time specified must be reasonable in light of all of the circumstances. View "Deangelo v. Souza" on Justia Law