Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) holding that Defendant was not deprived of due process when the circuit court refused to hold a hearing during trial as to whether Defendant was incompetent pursuant to Haw. Rev. Stat. 704-404, holding that the circuit court abused its discretion.Defendant was charged with one count of sexual assault in the first degree. During trial, Defendant's counsel informed the circuit court of his belief that Defendant was not fit to proceed. The circuit court denied the motion, and Defendant was found guilty. Defendant filed a motion for a new trial, arguing that he was incompetent during his trial. The motion was denied. The ICA remanded the case to have the circuit court determine whether Defendant was competent at the time of his trial. The Supreme Court vacated the ICA's judgment, holding that there was ample evidence subsequent to trial supporting Defendant's motion for a new trial. View "State v. Fleming " on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court denying Appellant's motions in limine to offer hearsay evidence, holding that the circuit court did not err in denying the motions without entering findings of fact on the record.On certiorari, Appellant argued that the ICA erred by concluding that the circuit court may deny a motion in limine without providing findings of fact on the record in violation of Haw. R. Pen. P. 12(e). The Supreme Court affirmed, holding (1) Rule 12(e) does not govern motions in limine; and (2) Haw. R. Evid. 103(b), the specific standard governing the admissibility of evidence and motions in limine, provides discretion to trial courts resolving evidentiary issues regarding whether to make findings of fact. View "State v. Marroquin" on Justia Law

In this custody dispute, the Supreme Court vacated a settlement agreement reached by the parties during trial, holding that the family court's actions in reaching the settlement were improper, and thus the family court plainly erred.Father sought joint legal and physical custody of the parties' minor child, and the case proceeded to a bench trial. The parties settled during trial. On appeal, Father argued that the family court acted improperly in facilitating the settlement. The Supreme Court agreed, holding that because the court spoke to Father alone without obtaining consent from counsel on the record, initiated settlement discussions, and strongly recommended specific terms on a hotly-contested issue after trial had commenced, the family court committed plain error. View "WW v. DS" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the family court's order granting the Department of Human Services (DHS) foster custody and the subsequent order terminating Mother's parental rights, holding that the ICA erred when it failed to vacate the family court's order.On appeal, Mother argued that the family court erred in failing to appoint counsel for her prior to granting foster custody. The Supreme Court agreed, holding (1) Mother should have been appointed counsel at the time DHS filed its petition for family supervision; and (2) the failure to appoint Mother counsel at the time DHS filed its petition for foster custody was structural error that cannot be deemed harmless. The Supreme Court remanded the case for further proceedings. View "In re L.I." on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction of operating a vehicle under the influence of an intoxicant (OVUII), Haw. Rev. Stat. 291E-61(a)(1), holding that any error not taking judicial notice that thirty mph was equivalent to forty-four feet per second was harmless.During trial, Defendant's attorney asked the district court to take judicial notice that sixty miles per hour was equivalent to eighty-eight feet per second as a matter that is generally known. The court appeared to conclude that it could not take judicial notice of the conversion and that Defendant would have to present expert testimony. The Supreme Court affirmed, holding that trial courts are required to take judicial notice of equivalent measurements unless provided with the mathematical equation for conversion, but the error in this case was harmless. View "State v. Kwong" on Justia Law

The Supreme Court affirmed in part and vacated in part the intermediate court of appeals' (ICA) judgment on appeal with respect to defendant Nicole Jadan's counterclaim and vacated the district court's judgment, holding that the district court erred by failing to determine whether Jadan's participation in the court proceedings would be meaningful absent language assistance when it resolved her repeated requests for an interpreter.Cambridge Management filed a complaint for writ of possession against Jadan. Jadan counterclaimed for damages. The district court held nine hearings on the complaint and counterclaim. At eight of those court dates, Jadan either requested the assistance of a Polish interpreter or indicated to the court that she struggled with understanding and communicating in English. One judge agreed to appoint an interpreter midway through the district court proceedings, but subsequent court dates proceeded without the service of an interpreter. The court ruled in favor of Cambridge. The ICA affirmed. The Supreme Court vacated in part, holding that the district court's failure adequately to inquire into Jadan's language access needs was not harmless. View "Cambridge Management Inc. v. Jadan" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) vacating the circuit court's order granting Defendant's motion to suppress evidence obtained in a search of Defendant's bedroom, holding that the circuit court erred in suppressing all evidence obtained by the State.In granting Defendant's motion to suppress, the circuit court determined that Defendant possessed a reasonable expectation of privacy in his bedroom and that the police officer coerced Defendant into opening his bedroom door. The court then suppressed all statements, evidence, observations and actions that were obtained after entry into the bedroom. The ICA vacated the circuit court's order, holding that an emergency aid exception justified the warrantless search. The Supreme Court affirmed on different grounds, holding that, even if the officers unlawfully searched Defendant's bedroom, the evidence obtained did not constitute suppressible "fruit of the poisonous tree." View "State v. Lee" on Justia Law

The Supreme Court affirmed the final judgment of the circuit court dismissing, for lack of jurisdiction, Petitioner's petition to impeach Honolulu City Prosecutor Keith Kaneshiro under section 12-203 of the Revised Charter of the City and County of Honolulu, holding that Hawaii's Uniform Electronic Transactions Act (UETA), Haw. Rev. Stat. Chapter 489E, did not apply to the petitions for impeachment in this case.Haw. Rev. Stat. 489E-7(d) states, "If a law requires a signature, an electronic signature satisfies the law." However, Haw. Rev. Stat. 489E-18(c) states that the UETA "does not require a governmental agency of this State to use or permit the use of electronic records or electronic signatures." In his motion to dismiss, Kaneshiro argued that electronic signatures did not satisfy the requirements for a petition to impeach the city prosecutor. The circuit court granted the motion, concluding that signatories to an impeachment petition under section 12-203 of the Revised Charter must provide handwritten signatures. The Supreme Court affirmed, holding that the UETA did not apply in this case. View "Yoshimura v. Kaneshiro" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the circuit court's order denying Petitioner's petition to vacate, set aside, or correct illegal sentence through a writ of habeas corpus pursuant to Haw. R. Penal P. 40, holding that counsel did not properly advise Petitioner about the consequences of an aggravated felony conviction.Petitioner pleaded no contest to theft in the first degree, an aggravated felony under federal immigration law, and to welfare fraud. Petitioner's counsel's advice conveyed that there was a realistic possibility Petitioner would not be deported, but, in reality, Petitioner was precluded from discretionary relief from deportation due to her conviction. The Supreme Court held that Petitioner was entitled to relief under the totality of the circumstances and offered guidance as to an issue relating to qualifications of interpreters. View "Araiza v. State" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the Labor and Industrial Relations Appeal Board's (LIRAB) denial of Petitioner's request to reopen her workers compensation claims pursuant to Haw. Rev. Stat. 386-89, holding that the LIRAB's finding that Petitioner failed to provide substantial evidence of a mistake was clearly erroneous.After her employment was terminated Petitioner was diagnosed with a disease known as multiple chemical sensitivity (MCS). Petitioner filed multiple claims for workers' compensation benefits. At issue was the LIRAB's denial of Petitioner's request to reopen her claims and the ICA's affirmance of the denial. The LIRAB determined that Petitioner failed to produce substantial evidence to support her allegations of a mistake in fact related the the LIRAB director's determination that Petitioner had not suffered a compensable illness because MCS is not an "injury per se." The Supreme Court vacated the ICA's affirmance of the LIRAB's finding that Petitioner failed to provide substantial evidence of a mistake, holding that there was substantial evidence supporting Petitioner's contention that it was a mistake to dispose of her claims on the basis that MCS is not a legitimate diagnosis. View "Porter v. Queen’s Medical Center" on Justia Law