Justia Hawaii Supreme Court Opinion Summaries

Petitioner Kevin Yamahata was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant (OVUII) in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeal (ICA) affirmed. Yamahata appealed, contending that the ICA gravely erred in holding that mens rea need not be alleged in either a section 291E-61(a)(1) or (a)(3) charge pursuant to State v. Nesmith. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Yamahata's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Yamahata did not challenge the sufficiency of the evidence as to that basis, his conviction still stood. View "State v. Yamashita " on Justia Law

Petitioner James Flynn was found guilty of operating a vehicle under the influence of an intoxicant in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) pursuant to State v. Nesmith, the ICA erred by concluding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and without such allegation, Flynn's section 291E-61(a)(1) charge was fatally deficient; but (2) insofar as Flynn's conviction under the alternative charge based upon subsection 291E-61(a)(3) was sufficient, and insofar as Flynn did not challenge the sufficiency of the evidence as to that basis, his conviction under subsection (a)(3) stood. View "State v. Flynn " on Justia Law

Petitioner Tommy Bullard was convicted of operating a vehicle under the influence of an intoxicant (OVUII) in violation of Haw. Rev. Stat. 291E-61(a)(1). The intermediate court of appeals (ICA) affirmed. The Supreme Court accepted Bullard's application for writ of certiorari and vacated the judgment of the ICA, holding (1) pursuant to State v. Nesmith, which holds that an OVUII charge under section 291E-61(a)(1) must allege mens rea, the ICA erred by concluding that mens rea need not be alleged in a section 291E-61(a)(1) charge; and (2) without such allegation, Bullard's charge was fatally deficient. Remanded to the district court with instructions to dismiss without prejudice. View "State v. Bullard " on Justia Law

Petitioner Emilio Soria was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1). The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's judgment, holding that pursuant to State v. Nesmith, which states that mens rea must be alleged in a section 291E-61(a)(1) charge in order to provide fair notice of the nature and cause of the accusation, the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge. Therefore, Shinsato's section 291E-61(a)(1) charge was deficient for failing to allege mens rea. Remanded to the district court with instructions to dismiss the complaint without prejudice. View "State v. Soria " on Justia Law

Petitioner Rew Shinsato was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Shinsato's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Shinsato did not challenge the sufficiency of the evidence as to that basis, Shinsato's conviction still stood. View "State v. Shinsato " on Justia Law

Petitioner Alejandro Padilla was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Padilla's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Padilla did not challenge the sufficiency of the evidence as to that basis, Padilla's conviction still stood. View "State v. Padilla " on Justia Law

Petitioner William Daniels was adjudged guilty of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Daniels' section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Daniels did not challenge the sufficiency of the evidence as to that basis, Daniels' conviction still stood. View "State v. Daniels " on Justia Law

Landowners brought this lawsuit against their neighbor, seeking compensation for property damage caused by the neighbor, and seeking a determination of access and water rights. The application before the Supreme Court, however, raised questions concerning procedural aspects of the hearings before the trial court and of the appeal to the intermediate court of appeals (ICA). The first question concerned pleading standards of appellate briefs, and the remaining questions addressed the trial court's determination of which parties must participate in a lawsuit, and the procedure an appellate court should follow when reviewing that determination. The Court reversed the decision of the ICA and reinstated the trial court's order, holding (1) the ICA did not err in reviewing the defendants' points of error on appeal; but (2) the ICA erred in vacating the trial court's final judgment. View "Marvin v. Pflueger" on Justia Law

Kevin Nesmith and Chris Yamamoto were each charged with operating a vehicle under the influence of an intoxicant (OVUII) pursuant to Haw. Rev. Stat. 291E-61(a)(1) and/or (a)(3). The trial court found Nesmith and Yamamoto guilty as charged. Nesmith and Yamamoto appealed, alleging that the complaints were legally deficient for having failed to allege mens rea. The intermediate court of appeals (ICA) affirmed, holding that mens rea need not be alleged in a complaint charging crimes under sections 291E-6a(a)(1) and/or (a)(3). The Supreme Court consolidated the cases and held (1) pursuant to State v. Wheeler, a charge of OVUII under section 291E-61(a)(1) must allege the requisite mens rea; (2) an OVUII charge under section 291E-61(a)(3) is an absolute liability offense for which mens rea need not be alleged or proven; (3) the ICA erred by relying on general intent cases to hold that mens rea may be inferred from the allegations in a section 291E-61(a)(1) OVUII charge; and (4) the State v. Nesmith majority erred by extending Haw. Rev. Stat. 806-28 to the district courts. View "State v. Yamamoto" on Justia Law

Defendant Pulumata'ala Eli was convicted of attempted manslaughter. Defendant appealed, arguing that the trial court erred by failing to suppress a statement Defendant made to a detective in violation of his rights under Miranda v. Arizona. The Supreme Court vacated the circuit court's judgment of conviction and sentence, holding (1) the police practice of inviting an arrestee to make a statement and to give his or her "side of the story" or similar entreaties in a "pre-interview" before Miranda warnings are given violates the defendant's constitutional right against self-incrimination and right to due process; and (2) under the circumstances of this case, the Mirandized statement offered into evidence at trial resulted from the exploitation of the said pre-interview practice, and the Miranda warnings subsequently given did not remove the taint of such practice. Remanded for a new trial. View "State v. Eli" on Justia Law