Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court vacated the intermediate court of appeals' (ICA) judgment on appeal and the circuit court's judgment of conviction and sentence, holding that the circuit court erred in admitting a portion of the complaining witness's testimony and that the error was not harmless beyond a reasonable doubt.Defendant was indicted for one count of sexual assault in the first degree and one count of sexual assault in the third degree. The jury found Defendant guilty on both counts. The ICA affirmed. On appeal, Defendant argued that a portion of the complaining witness's (CW) testimony was not properly admitted for the purpose of bolstering the credibility of the CW's account of the incident. The Supreme Court agreed, holding that the cited testimony was not relevant to the witness's credibility, and the erroneous admission of the testimony was highly prejudicial to the defense. View "State v. Lora" on Justia Law

In this appeal stemming from James Smith's "complaint to initiate special proceeding," the Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's final judgment dismissing Smith's complaint, holding that the circuit court should have construed Smith's complaint as an original action under Haw. Rev. Stat. 92-12(c) seeking declaratory relief.The circuit court granted the motion for judgment on the pleadings filed by the Office of Information Practices (OIP), concluding that it did not have jurisdiction to hear Smith's appeal and that Smith's remedies lay in Haw. Rev. Stat. 92-12. The ICA affirmed. The Supreme Court held (1) although Smith, at times, referred to his complaint as a Haw. Rev. Stat. 92F-43 appeal, it contained numerous references to Haw. Rev. Stat. Ch. 92, the Sunshine Law at issue in the OIP opinion, and therefore, the circuit court should have construed the complaint as an original action seeking declaratory relief; (2) the ICA erred in ruling that Smith was not permitted to name OIP as a defendant; and (3) the "palpably erroneous" standard, rather than the "de novo" standard, applies to a review of OIP opinions pursuant to a seciton 92-12(c) lawsuit. View "In re Office of Information Practices Opinion Letter No. F16-01" on Justia Law

The Supreme Court vacated the intermediate court of appeals' (ICA) judgment on appeal and the circuit court's judgment of conviction and sentence, holding that Defendant's fundamental due process right to present a complete defense was violated when the circuit court prohibited Defendant from presenting state of mind evidence relevant to his self-defense claim.Defendant was convicted of the attempted murder in the second degree of David Quindt, Jr. The attempted murder charge arose from an altercation between Defendant and Quindt, and the primary disputed issue at trial was whether Defendant acted in self-defense. The ICA affirmed the convictions. Before the Supreme Court, Defendant argued that the circuit court erred by prohibiting him from presenting evidence relevant to his self-defense claim, in violation of his constitutional right to present a complete defense. The Supreme Court agreed and reversed, holding that the circuit court erred in altering and excluding Defendant's state of mind evidence, and the error was not harmless beyond a reasonable doubt. View "State v. Williams" on Justia Law

The Supreme Court reversed Defendant's conviction of promoting a dangerous drug in the third degree, holding that Defendant's due process right to a fair trial was implicated by the lack of a correction of a police officer's false testimony before conclusion of trial, and the error was not harmless.Defendant appealed the circuit court's denial of his motion for a new trial, asserting that he met the intermediate court of appeals' (ICA) four-part test for a new trial based on false testimony from a material prosecution witness and that his right to a fair trial was violated because Officer Douglas Korenic testified falsely during trial. The ICA affirmed. The Supreme Court reversed, holding (1) Defendant satisfied the ICA's four-part test for a new trial based on false testimony from a material prosecution witness under State v. Teves, 679 P.2d 136 (1984); and (2) Defendant's right to a fair trial was violated because Officer Korenic gave false testimony, and there was a reasonable possibility the false testimony contributed to Defendant's conviction. View "State v. Stone" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) as well as the district court's judgment convicting Defendant of operating a vehicle under the influence of an intoxicant (OVUII), holding that certain evidence was inadmissible under Haw. R. Evid. 608(b)..At trial, Defendant's counsel sought to impeach the credibility of police officer Jared Spiker under Rule 608(b), arguing that the "specific instances of conduct" evincing Officer Spiker's untruthfulness were contained in transcripts from three other proceedings in which Officer Spiker was a witness for the state. The district court refused to allow defense counsel to cross-examine Officer Spiker concerning these proceedings. The ICA upheld the evidentiary rulings, holding that the district court had in its possession materials concerning the three other proceedings and therefore did not abuse its discretion in preventing further cross-examination of Officer Spiker concerning his testimony in those proceedings. The Supreme Court reversed, holding (1) the district court erred in finding that two of the prior proceedings were not probative of Officer Spiker's credibility; and (2) to the extent the ICA suggested that the district court reached its judgment by taking into account evidence it had excluded, such suggestion is wrong. View "State v. Su" on Justia Law

The Supreme Court reversed Defendant's conviction for violating Revised Ordinances of Honolulu (ROH) 29-5.1 for engaging in business on any public sidewalk where Defendant's operation tended to or did impede or inconvenience the public or any person, holding that the conviction was not supported by substantial evidence.Defendant set up a table at the edge of the sidewalk along Kalakaua in Waikiki to perform a painting demonstration and showcase his art for sale. A crowd formed to watch as Defendant worked, and some pedestrians were forced to detour around the spectators. The district court convicted Defendant for violating ROH 29-5.1. On appeal, Defendant argued that the district court erroneously included the spectators as part of his "operation." The Supreme Court agreed, holding (1) a defendant's operation does not include spectators over which a defendant has no control; and (2) because there was no evidence that Defendant's operation, excluding spectators, impeded or inconvenienced any person, Defendant's conviction was not supported by substantial evidence. View "State v. Zowail" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction for two counts of sexual assault in the first degree for molesting a minor child, holding that the testimony of Dr. Alexander Bivens, the State's expert witness in child sexual assault dynamics, did not improperly profile Defendant as a child molester.The challenged testimony was not introduced during the State's case-in-chief but, rather, was elicited by the defense during cross-examination. The State further developed that testimony on redirect examination without any objection by the defense. On appeal, Defendant argued that the testimony impermissibly bolstered the child's credibility and improperly profiled him as a molester. The ICA affirmed, concluding that the testimony neither impermissibly profiled nor unduly prejudiced Defendant. The Supreme Court affirmed, holding (1) Defendant did not properly preserve his claim about bolstering and waived his ability to challenge the statements under Haw. R. Evid. 103(a)(1); (2) under plain error review, Defendant's substantial rights were not affected; and (3) the testimony did not improperly profile Defendant as a child molester. View "State v. Engelby" on Justia Law

The Supreme Court remanded this criminal matter to the circuit court for further proceedings, holding that the circuit court erred by denying Defendant's motion to suppress as to certain drug evidence.Defendant was convicted of one count of promoting a dangerous drug in the second degree and one count of unlawful use of drug paraphernalia. The intermediate court of appeals (ICA) affirmed. On certiorari, the Supreme Court noticed plain error affecting Defendant's substantial rights with respect to the circuit court's denial of Defendant's motion to suppress. The Court held (1) a dog sniff conducted by the Kauai Police Department (KPD) was unrelated to the initial stop and seizure of the truck driven by Defendant for evidence of the alleged theft of a purse; (2) KPD did not have independent reasonable suspicion to believe the truck contained drugs; and (3) therefore, the dog sniff violated Defendant's constitutional right against unreasonable searches. View "State v. Ikimaka" on Justia Law

The Supreme Court vacated the decision of the Public Utilities Commission (PUC) approving an application for a rate increase submitted by Hawai'i Gas (HG) and remanded this case to the PUC for further proceedings, holding that the PUC did not fulfill its statutory obligations under Haw. Rev. Stat. 269-6(b).Specifically, the Supreme Court held (1) as "persons aggrieved" who participated in the contested case, Appellants had standing to appeal; (2) PUC failed to carry out its mandate under section 269-6(b); (3) the PUC's limitations in sub-issue No. 1h violated Appellants' due process rights by improperly curtailing Appellants' substantive participation; and (4) the PUC did not abuse its discretion in adjudicating HG's rate case rather than proceeding through rule-making. View "In re Application of The Gas Company, LLC" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals affirming the judgment of the circuit court convicting Defendant of assault in the second degree, holding that Defendant's constitutional right to cross-examine witnesses was violated when the circuit court prevented defense counsel from cross-examining the complainant about a potential source of bias.On appeal, Defendant argued that the circuit court erred in precluding the defense from cross-examining the complainant about disciplinary action the complainant might have faced as a United States Marine for instigating a fight in violation of its code of conduct provisions. Defendant further argued that the court erred in allowing a police officer to testify as to the contents of a security video that recorded the altercation but that had subsequently been destroyed. The ICA affirmed. The Supreme Court reversed, holding that because the defense was prevented from questioning the complainant about a potential source bias, the jury did not have sufficient information from which to make an informed appraisal of the complainant's motives or bias. The Court also provided guidance concerning the admissibility of other evidence as to the contents of a destroyed video recording under Haw. R. Evid. R. 1004 and 403. View "State v. Miranda" on Justia Law