Justia Hawaii Supreme Court Opinion Summaries

In this case arising from settlement negotiations between Plaintiff and Defendants relating to a dispute about water and mold damage to Plaintiff's condominium the Supreme Court remanded this case with instruction that the circuit court hold an evidentiary hearing to address issues of fact as to the terms and existence of a purported settlement agreement between the parties.At the close of a settlement conference, the circuit court and the parties acknowledged that the parties had reached a settlement. Plaintiff, however, refused to sign the settlement documents and proceeded to represent herself pro se. Defendants filed a motion to enforce the settlement agreement. The circuit court granted the motion, concluding that the parties had entered into a binding settlement agreement but that the proposed written settlement agreement contained terms beyond those agreed to at the settlement conference. Therefore, the court struck those terms and created a revised settlement agreement. The Supreme Court remanded the case, holding that because genuine issues of material fact existed as to whether the parties reached a valid settlement agreement and as to which terms the parties agreed to at the settlement conference, the circuit court should have granted Plaintiff's motion for an evidentiary hearing to resolve those issues. View "McKenna v. Association of Apartment Owners of Elima Lani" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that Defendant's privilege against self-incrimination was infringed when the circuit court permitted the jury to view a video of Defendant invoking that privilege.Defendant was charged with attempted murder in the second degree and assault in the first degree as a result of an altercation with another person during which Defendant allegedly punched and kicked that person multiple times. During trial, the State played for the jury a video of a detective interviewing Defendant that concluded with Defendant declining the detective's request that Defendant reenact the altercation. The jury convicted Defendant of attempted murder in the second degree. The ICA affirmed. The Supreme Court remanded the case for a new trial, holding that Defendant invoked his right to remain silent when he declined to participate in a reenactment of the encounter and that his right to do so was infringed when the prosecution played the police interview video before the jury at trial. View "State v. Beaudet-Close" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction of operating a vehicle under the influence of an intoxicant (OVUII), holding that admissibility of evidence under Haw. R. Evid. 608(b) involves a two-step inquiry and that the ICA erred to the extent that it suggested a trial court can consider excluded evidence in reaching judgment.At trial, defense counsel sought to impeach the credibility of one of the State's witnesses under Rule 608(b). Counsel argued that specific instances of conduct evincing the witness's untruthfulness were contained in transcripts from three other proceedings in which he was a witness for the State. The district court refused to allow defense counsel to cross-examine the witness concerning these proceedings. The ICA upheld the evidentiary rulings, noting that the district court was able to review the materials concerning the three proceedings. The Supreme Court remanded this case to the district court, holding (1) the district court erred in precluding defense counsel from cross-examining that witness as to two of the proceedings; 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 vacated the opinion of the Intermediate Court of Appeals (ICA) vacating the circuit court's order granting Defendant's motion to suppress all evidence seized as a result of the execution of a search warrant, holding that the amount of time afforded to Defendant to respond to police officers' demand for entry was not reasonable.Police officers broke down Defendant's front door at approximately 6:15 a.m. after they knocked, announced their presence, and demanded entry four times within a twenty-five-second period. The officers had no reason to believe that Defendant was fleeing or that any evidence was being destroyed. Defendant, who was charged with drug offenses, filed a motion to suppress, arguing that the execution of the warrant violated Haw. Rev. Stat. 803-37 and Haw. Const. art. I, 7. The circuit court granted the motion to suppress. The ICA vacated their circuit court's order, concluding that Defendant was afforded a reasonable amount of time to respond to the police's demand for entry to serve the search warrant. The Supreme Court disagreed, holding (1) giving an occupant only twenty-five seconds to respond at such an early morning hour was unreasonable; and (2) there were no exigent circumstances that would have justified breaching the door earlier than would have otherwise been reasonable. View "State v. Naeole" on Justia Law

In this ejectment action, the Supreme Court granted Appellant's motion for in forma pauperis (IFP) status on appeal, vacated the Intermediate Court of Appeals' (ICA) order dismissing appeal, and remanded this case to the ICA for further proceedings consistent with this opinion, holding that the ICA abused its discretion in ordering Appellant to file IFP motions in the district court, in denying Appellant's second IFP motion based on Haw. Rev. Stat. 607-3 and Haw. R. App. P. 24, and then in dismissing her appeal.Appellant, a self-represented defendant in a residential ejectment case, appealed a judgment and writ of possession filed by the district court. Appellant filed two motions to proceed IFP. The ICA denied both motions and ordered Appellant either to file an IFP motion in the district court within ten days or pay the filing fees in full. When Appellant did neither, the ICA dismissed Appellant's appeal. The Supreme Court reversed, holding that when courts have discretion in applying court rules or statutes, they must consider the access to justice principle of reducing barriers to the civil justice system for self-represented litigants. View "Estate Administrative Services LLC v. Mohulamu" on Justia Law

The Supreme Court vacated the Intermediate Court of Appeals' (ICA) judgment on appeal and the circuit court's amended judgment convicting Defendant of burglary in the first degree, holding that Defendant was denied the right to effective assistance at trial.On appeal, Defendant argued that her trial counsel provided ineffective assistance by failing to adduce critical evidence impeaching the credibility of the State's key witness. The Supreme Court agreed and vacated Defendant's conviction, holding that, when viewed as a whole, the adequacy of counsel's representation was not within the range of competence demanded of counsel in criminal cases. View "State v. Salavea" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for murder in the second degree, holding that third party culpability evidence was erroneously excluded, but the error was harmless beyond a reasonable doubt.On appeal, Defendant asserted (1) the trial court abused its discretion by excluding evidence tending to show that a third party committed the offense; (2) the trial court erred by admitting into evidence a confession letter allegedly written by Defendant because of its late disclosure to the defense; and (3) DNA results showing Defendant's presence at the crime scene were improperly admitted at trial. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admitting the confession letter at trial because the timing of the State's disclosure did not require exclusion; (2) a sufficient foundation to admit the results of the DNA analyses was established to allow their admission into evidence; and (3) evidence of the third party's culpability was improperly excluded, but the exclusion was harmless beyond a reasonable doubt. View "State v. Texeira" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the judgment of the circuit court convicting Defendant of reckless endangering in the second degree, holding that the circuit court erred by excluding Defendant from presenting third-party culpability evidence at trial.In precluding Defendant from presenting third-party culpability evidence the circuit court determined that the evidence failed to establish a "legitimate tendency" that the third party committed the crime. The Supreme Court vacated Defendant's conviction, holding (1) admissibility of third-party culpability evidence is properly governed by Haw. R. Evid. 401 and 403, without having also to satisfy a legitimate tendency test; (2) the circuit court erred in precluding the defense from adducing third-party culpability evidence that another person assaulted the complaining witness; and (3) the circuit court and the ICA improperly weighed the third-party culpability evidence offered by Defendant. View "State v. Kato" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the judgment of the circuit court convicting Defendant of sexual assault in the first degree and sexual assault in the third degree, holding that Defendant's confession should not have been admitted against him at trial.Defendant gave his confession during a custodial interrogation. At issue on appeal was whether Defendant's constitutional right against self-incrimination was violated by the admission of his confession. The ICA affirmed the circuit court's ruling that the confession was voluntarily given. The Supreme Court reversed, holding (1) due to law enforcement's coercive tactics and deception about incontrovertible physical evidence Defendant's confession was involuntary under the totality of the circumstances; and (2) the admission of Defendant's statement was not harmless error. View "State v. Baker" on Justia Law

In this appeal challenging the circuit court's grant of Defendant's ex parte oral motion to dismiss a personal injury action with prejudice, the Supreme Court held that the circuit court abused its discretion in granting Defendant's motion to dismiss.Plaintiff, a pro se litigant, filed a personal injury claim against Defendant. During a pretrial conference at which Plaintiff did not attend Defendant filed his oral motion to dismiss. The trial court granted the motion. The Supreme Court reversed, holding (1) the circuit court abused its discretion in granting Defendant's oral motion to dismiss with prejudice because the record did not provide a valid basis for the dismissal order, and the court failed to make the request findings of fact that would be required to support such an order; and (2) in general, motions must be made in writing with notice provided unless the motion is made during a hearing or trial. View "Erum v. Llego" on Justia Law