Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) vacating the circuit court's judgment of conviction and sentence and remanding the case to the circuit court for further proceedings, holding that the appellate court erred in part.Defendant was convicted of computer fraud in the third degree and fraudulent use of a credit card and sentenced to five years in prison. The ICA vacated Defendant's convictions and remanded the case. The Supreme Court vacated the ICA's judgment in part, holding (1) the ICA properly held that aggregation of multiple transactions under computer fraud in the third degree is permissible; and (2) the indictment was defective with respect to the count alleging computer fraud, and therefore, the denial of Defendant's motion to dismiss the indictment was error. View "State v. Shaw" on Justia Law

The Supreme Court vacated Defendant's conviction for assault in the first degree and remanded this case to the circuit court, holding that the trial court erred in conditioning the admission of evidence on expert testimony.Defendant killed his cousin, Santhony Albert, but claimed he had acted in self-defense. Defendant was convicted of assault in the first degree, and intermediate court of appeals affirmed. On appeal, Defendant argued that the trial court erred in preventing him from advancing evidence of Albert's blood alcohol concentration (BAC) level unless he called an expert to explain its meaning. The Supreme Court agreed, holding that the trial court erred in conditioning the BAC evidence on expert testimony and violated Defendant's constitutional right to present any and all competent evidence to support his defense. View "State v. David" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder for the death of a minor, holding that, contrary to Defendant's contention on appeal, the jury's answer to a special interrogatory was reconcilable with its verdict that Defendant was guilty of second-degree murder.In its jury instructions, the trial court instructed the jury on the lesser included offenses of second-degree murder, including third-degree assault. The statute defining third-degree assault, Haw. Rev. Stat. 707-712, states that the offense may be reduced to a petty misdemeanor if the altercation is the result of "mutual affray." The circuit court submitted a special interrogatory to the jury on mutual affray and instructed the jury that it must answer the special interrogatory only if it found Defendant guilty of third-degree assault. The jury found Defendant guilty of second-degree murder and answered the special interrogatory in the negative. Defendant filed motion for a new trial, arguing that the jury's inconsistent verdict required that his convictions be vacated. The Supreme Court affirmed, holding that the evidence could have reasonably caused the jury to conclude that the altercation leading to the decedent's death began as mutual affray but ended in second-degree murder. View "State v. Bringas" on Justia Law

The Supreme Court affirmed Defendant's conviction for burglary, holding that the prosecutor committed misconduct but that the evidence overwhelmingly established Defendant's guilt.During Defendant's trial, the prosecution injected victim impact evidence, spotlighting the crime's effect on the burglarized family and focusing its narrative arc on the victims' emotional state and actions after the crime. The prosecutor also told jurors that defense counsel tried to "trick" him. On appeal, Defendant argued that prosecutorial misconduct required that his conviction be vacated. The Supreme Court affirmed, holding (1) the prosecutor committed serious misconduct during trial; but (2) considering the strength of the evidence against Defendant, the misconduct had no reasonable possibility of contributing to Defendant's conviction. View "State v. Riveira" on Justia Law

The Supreme Court vacated Defendant's conviction of possession of methamphetamine and of drug paraphernalia, holding that the admission of certain testimony contravened Haw. R. Evid. 404(b) and 403 because it was propensity evidence that suggested that Defendant was a drug dealer.During trial, Amy Bautista, Defendant's girlfriend, testified for the State about Defendant's prior drug activity. On appeal, Defendant challenged that circuit court's admission of Bautista's statements admitted as prior bad act evidence. The intermediate court of appeals affirmed. The Supreme Court vacated the judgments below, holding that the circuit court abused its discretion when it determined that the probative value of the evidence substantially outweighed its prejudicial effect and that Defendant was entitled to a new trial. View "State v. Villados " on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the circuit court's order denying Defendant's motion for a new trial, holding that the cumulative impact of misconduct on the part of the prosecutor deprived Defendant of a fair trial and was not harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) at trial, the prosecutor introduced to the jury incriminatory statements allegedly made by Defendant without previously disclosing them to the defense during discovery in violation of Haw. R. Pen. P. 16(b)(1); (2) the prosecutor introduced statements that were incriminating to Defendant that were allegedly made by the complaining witness despite the court's motion in limine ruling barring their introduction; (3) the prosecutor engaged in improper and unnecessarily lurid questioning of defense witnesses to inflame the jury's passions; and (4) the circuit court erred in denying Defendant's motion for a new trial based on prosecutorial misconduct, and the ICA erred in concluding that the prosecutor's misconduct was harmless. View "State v. Williams" on Justia Law

The Supreme Court vacated the order of the intermediate court of appeals (ICA) affirming the order of the family court convicting Defendant of abuse of family or household member, holding that the improper admission of certain evidence was not harmless beyond a reasonable doubt.Defendant's conviction stemmed from his act of striking the complaining witness, his wife, in the face. Before trial, the State sought to introduce "prior bad acts" evidence, specifically, a previous incident in which Defendant allegedly pushed his wife out of a chair. The family court ruled that the State could introduce the chair incident if the door was opened by Defendant. During trial, the chair incident was allowed into evidence. The ICA affirmed. The Supreme Court vacated the ICA's decision, holding (1) the ICA erred by ruling that Defendant "opened the door" to the chair incident evidence; (2) the ICA erred by ruling that the chair incident evidence was admissible under Haw. R. Evid. 404(b); (3) the family court's limiting instructions failed to mitigate the prejudicial impact of the chair incident evidence; and (4) the improper admission of the chair incident evidence was not harmless beyond a reasonable doubt. View "State v. Feliciano" on Justia Law

The Supreme Court vacated the summary disposition order of the intermediate court of appeals (ICA) and the order of the circuit court dismissing Appellant's Haw. R. Pen. P. 40 petition, holding that the circuit court erred in dismissing the petition without first providing Appellant an opportunity to clarify his claims.Appellant was convicted of second-degree murder and several other charges. While an inmate, Appellant filed a Rule 40 petition alleging, without any factual allegations, that he received ineffective assistance of counsel at trial. After the circuit court dismissed the petition as "patently frivolous and without a trace of support" Appellant moved to withdraw his petition so he could amend it to include factual allegations. The circuit court denied the motion to withdraw the petition, and the ICA affirmed. The Supreme Court vacated the lower courts' order, holding (1)the circuit court's order dismissing Appellant's petition for postconviction relief was premature because the court failed to provide Appellant with an opportunity clarify his petition before dismissing it; and (2) the motion to withdraw, which should have been construed as a motion to reconsider, should have been granted. View "Lindsey v. State " on Justia Law

The Supreme Court vacated Defendant's conviction and sentence for four counts of sexual assault in the second degree, holding that Defendant presented a "fair and just reason" for the withdrawal of his pleas of no contest to the counts.Before sentencing, Defendant moved to withdraw his no contest pleas, asserting that he was innocent and wanted a trial. The circuit court denied the motion, concluding that Defendant entered his pleas knowingly, voluntarily, and intelligently. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the trial court's judgment, holding that the trial court disregarded the principle that pre-sentence defendants are entitled to withdraw their pleas for any fair and just reason and that there was a fair and just reason for the withdrawal of Defendant's pleas. View "State v. Pedro" on Justia Law

In this appeal stemming from three separate criminal cases related to repeated violations of an injunction against harassment the Supreme Court vacated the circuit court's orders of resentencing and revocation of probation in two cases and vacated the circuit court's order sentencing Defendant in another case, holding that the circuit court erred.Defendant pled no contest in two cases to eleven counts of violating an injunction against harassment and was sentenced to probation. Two years later, Defendant was convicted of one count each of violating an injunction against harassment and of second-degree assault. At sentencing, the circuit court revoked Defendant's probation in the prior two cases based on Defendant had violated the terms of his probation. The court then sentenced Defendant to a total of seventeen years imprisonment. The Supreme Court vacated Defendant's sentence, holding that the record did not reflect that Defendant understood the consequences of stipulating to the State's motions to revoke probation and that the circuit court did not sufficiently justify the imposition of consecutive sentences for each count. View "State v. Sandoval " on Justia Law