Justia Hawaii Supreme Court Opinion Summaries

The State charged Defendant, a native Hawaiian, of operating a vehicle under the influence of an intoxicant (OVUII). Defendant appealed, arguing, among other things, that he was denied due process because the complaint did not allege the state of mind that the State was required to prove for the charge of OVUII. The intermediate court of appeals (ICA) affirmed Defendant’s conviction. The Supreme Court vacated the ICA’s judgment and vacated the circuit court’s judgment of conviction and sentence, holding that, inasmuch as the charge against Defendant did not allege the requisite state of mind that also was an essential fact of the offense of OVUII, the complaint must be dismissed without prejudice. Remanded with instructions to dismiss. View "State v. Rivera " on Justia Law

Petitioner was adjudged guilty of operating a vehicle under the influence of an intoxicant in violation of Haw. Rev. Stat. 291E-61(a)(1). Petitioner challenged the sufficiency of the complaint against her for the first time on appeal, alleging that section 291E-61(a)(1) was deficient for failing to allege mens rea. The intermediate court of appeals affirmed the district court’s judgment. The Supreme Court vacated the ICA’s judgment and remanded with instructions to dismiss the complaint against Petitioner without prejudice, holding that because the complaint failed to charge a requisite state of mind, the ICA’s judgment must be vacated and the charge dismissed without prejudice because it violated due process. View "State v. Avilla " on Justia Law

Defendant was charged with committing the offense of assault in the third degree and was convicted as charged. Defendant appealed, arguing that he was not adequately informed of his right to testify. The Supreme Court reversed and remanded for a new trial, holding (1) the district court’s right-to-testify colloquy was defective, and as a result, Defendant did not intelligently, knowingly, and voluntarily waive his right to testify; (2) the constitutional violation of Defendant’s right to testify was not harmless beyond a reasonable doubt; and (3) substantial evidence supported Defendant’s conviction, and the prohibition against double jeopardy did not preclude a retrial in this case. View "State v. Pomroy" on Justia Law

After a jury trial, Defendant was convicted of burglary in the first degree and unauthorized entry into motor vehicle in the first degree. According to the State, Defendant’s co-defendant entered Jennifer Kincaid’s garage and Jeffrey Sampson’s van, while Defendant was the getaway driver. Kincaid, the only witness who identified Defendant as the driver in the incidents, identified Defendant in a field show-up procedure conducted shortly after she reported the burglary. Defendant and his co-defendant were the only two suspects present at the field show-up, prior to which the police informed Kincaid that they had stopped a vehicle that matched her description. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the circuit court’s judgment of conviction and sentence, holding that, under the particular circumstances of this case, the circuit court abused its discretion in refusing to give a specific instruction on field show-up identifications. Remanded. View "State v. Cabinatan" on Justia Law

The family court convicted Defendant of harassment in violation of Haw. Rev. Stat. 711-1106(1)(a). The intermediate court of appeals (ICA) vacated the family court’s judgment of conviction and sentence, holding that the complaint did not sufficiently apprise Defendant of what he must be prepared to meet because the language was worded in the disjunctive. The Supreme Court vacated the ICA’s judgment and affirmed the family court’s judgment, holding that, pursuant to State v. Codiamat, which held that a charge worded disjunctively in the language of the statute provides sufficient notice so long as the acts charged are reasonably related and are contained in a single subsection of a statute, the State’s charge provided Defendant with sufficient notice of what he must be prepared to meet. View "State v. Lockey " on Justia Law

The State charged three defendants (collectively, Petitioners) of entering or remaining within the Kaho’olawe Island Reserve without being specifically authorized to do so, thereby committing the offense of entrance into the reserve. Petitioners filed a motion to dismiss, which the trial court denied. Petitioners were found guilty of the charges. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment of the ICA and the district court, holding that although the sufficiency of the complaints was not raised by either party, the complaints must be dismissed without prejudice because the charges failed to charge that Petitioners acted with the requisite state of mind by violating the law intentionally, knowingly, or recklessly. View "State v. Armitage" on Justia Law

After a bench trial, Petitioner was convicted of abuse of a family or household member. On appeal, Petitioner argued that the family court did not ensure that he had “fully” waived his right to a jury trial. The intermediate court of appeals (ICA) affirmed, concluding that under the totality of the circumstances, Petitioner had validly waived his right to a jury trial. The Supreme Court vacated the ICA’s judgment and the family court’s judgment, holding that the family court failed to ensure that Petitioner’s waiver of his right to a jury trial was voluntary. Remanded for a new trial. View "State v. Baker" on Justia Law

Petitioner was convicted of excessive speeding and no motor vehicle insurance. Petitioner appealed, arguing that the State did not lay sufficient foundation for the admission of the laser gun reading. The intermediate court of appeals (ICA) affirmed. Petitioner appealed, arguing that the ICA gravely erred in holding that the State laid sufficient foundation for the admission of the laser gun reading and challenging, for the first time, the sufficiency of the charge in the amended complaint because the amended complaint did not allege the requisite state of mind. The Supreme Court vacated the judgments of the lower courts, holding that inasmuch as the amended complaint against Petitioner failed to allege the requisite state of mind, the amended complaint must be dismissed without prejudice. View "State v. Pai " on Justia Law

Defendant was tried for attempted murder in the second degree. During the proceedings, Defendant expressed his desire to proceed pro se. The circuit court determined that Defendant waived his right to counsel, and Defendant was pro se for the rest of the trial. After the jury returned a guilty verdict, Defendant’s standby counsel filed a motion to withdraw as standby counsel and that substitute counsel be appointed to assist Defendant post-trial and on appeal. The circuit court allowed standby counsel to withdraw but did not appoint substitute counsel for Defendant’s post-verdict motions or for sentencing. The Supreme Court remanded the case, holding that the circuit court erred (1) by not appointing substitute counsel for Defendant’s post-verdict motions because post-verdict proceedings are critical stages in the prosecution; and (2) by not appointing Defendant substitute counsel for sentencing. View "State v. Pitts" on Justia Law

Petitioner was convicted of excessive speeding. The intermediate court of appeals (ICA) affirmed. Petitioner sought review of the judgment of the ICA, challenging for the first time the sufficiency of the charge on the grounds that the amended complaint did not allege the required state of mind to prove the charge of excessive speeding. The Supreme Court vacated the judgments of the lower courts, holding that, inasmuch as the amended complaint against Petitioner failed to allege the requisite state of mind, which was an essential fact of the offense of excessive speeding, the amended complaint must be dismissed. View "State v. Pierce " on Justia Law