Justia Hawaii Supreme Court Opinion Summaries

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

The Supreme Court reversed in part the decision of the intermediate court of appeals (ICA) affirming the decision of the district court granting Defendant's motion to suppress his answers to the medical rule-out questions given subsequent to a traffic stop, holding that the ICA erred in affirming the district court's suppression of Defendant's answers to the medical rule-out questions.In granting Defendant's motion to suppress, the district court found that Defendant was subject to custodial interrogation without being given the required warnings under Miranda v. Arizona, 384 U.S. 436 (1966). The ICA affirmed. The Supreme Court reversed, holding that, under this Court's decision in State v. Sagapolutele-Silva, 511 P.3d 782 (Haw. 2022), Defendant was not in custody when he was asked the medical rule-out questions because the circumstances of the stop had not risen to those of a formal arrest. View "State v. Tronson " on Justia Law

The Supreme Court vacated in part the judgment of the intermediate court of appeals (ICA) affirming the district court's order granting Defendant's motion to suppress statements after finding that Defendant was subject to custodial interrogation without being given Miranda warnings, holding that the ICA erred in affirming the district court's suppression of Defendant's responses to medical rule-out questions.Defendant was arrested and charged with operating a vehicle under the influence of an intoxicant and reckless driving. Defendant moved to suppress his answers to the medical rule-out questions, asserting that he was subject to custodial interrogation without being given Miranda warnings. The ICA affirmed. The Supreme Court vacated the judgment in part, holding (1) because the circumstances of Defendant's stop did not rise to that of a formal arrest Defendant was not in custody at the time he was asked the medical rule-out questions; and (2) therefore, Miranda warnings were not required. View "State v. Vasconcellos " on Justia Law

The Supreme Court vacated Defendant's conviction for continuous sexual assault of a minor under the age of fourteen years, in violation of Haw. Rev. Stat. 707-733.6, holding that two of the deputy prosecuting attorney's closing argument remarks prejudiced Defendant's right to a fair trial.On appeal, Defendant argued that the deputy prosecuting attorney's remarks that (1) Defendant had a "motive to lie"; and (2) the complaining witness testified "consistent with a child who is traumatized" constituted plain error. The Supreme Court agreed and vacated his conviction, holding (1) both of the challenged remarks constituted prosecutorial misconduct; and (2) there was a reasonable possibility that each instance of misconduct, standing alone, contributed to the trial's outcome. View "State v. Hirata" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) in this criminal case, holding that because the information omitted the crime of forgery in the second degree's states of mind, it failed to state an offense as to counts 4-7 and violated Defendant's right to due process.Defendant was charged via information with four counts of forgery in the second decree. Defendant filed a pretrial motion to dismiss counts 4-7 charging him with forgery in the second degree because the information omitted forgery's states of mind. In response, the State argued that intent to defraud is an element, understandable to the common person, and gave notice to Defendant of forgery's state of mind. The circuit court granted Defendant's motion to dismiss. The ICA reversed. The Supreme Court reversed, holding (1) Defendant's information did not identify forgery's states of mind, intentionally and knowingly; and (2) therefore, counts 4-7 failed to state an offense and violated Defendant's right to due process. View "State v. Garcia" on Justia Law

The Supreme Court vacated in part the judgment of the intermediate court of appeals and the order of the circuit court denying Appellant's pro se Haw. R. Penal P. 40 petition challenging the sentencing court's judgment of conviction and sentence, holding that some of the grounds of Appellant's petition raised civil claims required to be transferred for disposition under the civil rules.Appellant pleaded guilty to multiple drug, theft, and firearm-related offenses, and the circuit court imposed concurrent prison terms and various monetary assessments. In his HRPP Rule 40 petition Appellant raised eight grounds challenging his conviction and sentence. The circuit court denied the petition without a hearing, and the intermediate court of appeals affirmed. The Supreme Court reversed, holding (1) the circuit court properly dismissed grounds one through five of Appellant's petition based on waiver; but (2) Appellant raised a colorable claim as to the monetary assessments; and (3) grounds six through eight raised civil claims required to be transferred for disposition under civil rules pursuant to HRPP Rule 40(c)(3). View "Warner v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Defendant's motion to dismiss the charges against him of, among other things, second-degree murder, holding that the State's prosecution of Defendant was unlawful under Haw. Rev. Stat. 801-1.On appeal from his convictions, Defendant argued that the State violated Haw. Rev. Stat. 801-1 by using the complaint and preliminary hearing process to prosecute him for second-degree murder, attempted murder in the first and second degree, and use of a firearm in the commission of a separate felony, holding (1) under section 801-1, criminal defendants cannot be "subject to be tried and sentenced to be punished in any court" for an alleged offense without an indictment or information, unless the charged offense is contempt or within the jurisdiction of the district court; and (2) defendants are "subject to be tried and sentenced to be punished" at arraignment. View "State v. Obrero" on Justia Law

The Supreme Court affirmed in part the judgment of the intermediate court of appeals (ICA) affirming the judgment of the circuit court convicting and sentencing Defendant but reversed with regard to the issue of Defendant's ability to pay a crime victim compensation (CVC) fee under Haw. Rev. Stat. 706-605(6) and 351-62.6, holding that Defendant's inability to pay the CVC fee mandated waiver of the fee.Defendant was convicted of various drug, theft, fraud, and property crimes. In addition to a five-year term of incarceration, the circuit court ordered Defendant to pay a CVC fee and a drug demand reduction (DDR) assessment under Haw. Rev. Stat. 706-650. Defendant appealed, arguing that both the CVC fee and the DDR assessment constituted unconstitutional taxes. The ICA affirmed. The Supreme Court vacated the ICA's judgment as to its imposition of the CVC and affirmed in all other respects, holding (1) the circuit court erroneously imposed the CVC fee upon Defendant because he was unable to pay the fee; and (2) the CVC fee and DDR assessment were not unconstitutional taxes. View "State v. Yamashita" on Justia Law