Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court vacated Defendant's conviction for operating a vehicle under the influence of an intoxicant, holding that the district court erroneously advised Defendant with regard to his right to testify in the context of a consolidated suppression hearing and trial.After he was charged, Defendant filed a motion to suppress statements he allegedly made to the police officer who arrested him. The district court consolidated the hearing on Defendant's motion to suppress with his bench trial and provided Defendant with several advisements about his right to testify. Defendant declined to testify, and the district court granted the motion to suppress in part. The court then found Defendant guilty. The intermediate court of appeals affirmed. The Supreme Court vacated Defendant's conviction and remanded the case for further proceedings, holding that Defendant did not knowingly, intelligently, and voluntarily waive his right to testify for the purposes of the pre-trial suppression hearing. View "State v. Chang" on Justia Law

The Supreme Court vacated Defendant's conviction, holding that litigants may not utilize another hearsay exception as an alternative to bypass the restrictions contained in the public records hearsay exception.While an exception to the evidentiary rule against hearsay typically allows public records to be admitted into evidence to prove the truth of their contents, the rule contains exclusions that ensure that law enforcement officers testify in person when the contents of their police reports are admitted as evidence in a trial. Another hearsay exception permits previously recorded recollections of a witness to be read into evidence when the witness is unable to sufficiently recall the subject matter of the statements to testify accurately at trial. Defendant was convicted on the sole basis of a police report authored by a law enforcement officer who testified at trial that he could no longer remember the material facts underlying Defendant's arrest. The Supreme Court vacated Defendant's conviction, holding that records excluded by the public records exception cannot be read into evidence based on an alternative evidentiary ground. View "State v. Abrigo" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) on appeal that affirmed the circuit court's judgment of conviction and sentence convicting Defendant of assault in the first degree, holding that the ICA correctly concluded that Defendant's conviction was supported by substantial evidence and that the circuit court's jury instructions were not prejudicially erroneous or misleading.While the Supreme Court concluded that the ICA properly upheld Defendant's conviction, it held that the ICA erred in that the circuit court sufficiently instructed the jury regarding unanimity and that therefore an additional unanimity instruction requested by Defendant was unnecessary. But because the instructions as a whole were not insufficient, inconsistent, erroneous, or misleading, the Supreme Court affirmed the ICA's decision affirming Defendant's conviction and sentence, further providing guidance that circuit courts specifically include the unanimity requirement in justification defense instructions. View "State v. Matuu" on Justia Law

In this case alleging violations of Hawaii's Sunshine Law, Haw. Rev. Stat. part of I of chapter 92, the Supreme Court affirmed in part and vacated in part the judgment of the circuit court dismissing Plaintiff's complaint against the Honolulu Police Commission and the City and County of Honolulu (collectively, Defendants), holding that the circuit court erred in dismissing the complaint.This action arose from three closed meetings the Honolulu Police Commission held in January 2017 concerning then-Chief of Police Kealoha, who was the target of a federal criminal investigation. At the end of the third meeting, the Commission approved an agreement for Kealoha's retirement. Plaintiff brought six counts against Defendants, seeking declaratory rulings interpreting Hawaii's Sunshine Law and alleging violations of the Sunshine Law. Plaintiff also sought an order requiring Defendants to attend Sunshine Law training, releasing the minutes for the closed meetings, and invalidating the Commission's agreement with Kealoha. Plaintiff did not join Kealoha as a party to the action. The circuit court granted Defendants' motion to dismiss. The Supreme Court resolved questions regarding the Sunshine Law on appeal and remanded Plaintiff's claims regarding alleged violations of the Sunshine Law with instructions to order that Kealoha be made a party. View "Civil Beat Law Center for Public Interest, Inc. v. City & County of Honolulu" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction for operating a vehicle under the influence of an intoxicant, holding that the ICA did not err in its ultimate conclusion that a colloquy was not required in this case before the trial court accepted the stipulation entered into between defense counsel and the State as to the arresting police officer's training and qualifications to conduct standardized field sobriety tests.The Supreme Court affirmed the ICA's judgment on appeal and the district court's judgment but upon the reasons set forth in this opinion. The Court held that while the ICA correctly held that a colloquy was not required in this case, it erred in setting forth an alternative holding that employed a novel test for evaluating prejudice resulting from a trial court's acceptance of a stipulation without a colloquy. The Court further provided guidance as to the proper allocation of authority between a defendant and defense counsel in light of the ICA's statements regarding defense counsel's authority to stipulate to an evidentiary matter based on trial "tactics and procedure." View "State v. Wilson" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) on appeal and affirmed the circuit court's order granting Petitioner's petition for post-conviction relief on the ground that the trial court's failure to conduct a colloquy with Defendant when accepting a stipulation to elements of the charged offense was plain error.Defendant was charged with drug-related crimes. During trial, the parties entered into a stipulation to elements of the charged offenses. The jury subsequently convicted Defendant on both charges. Defendant later filed a petition to vacate, set aside, or correct the judgment asserting that his constitutional rights to a fair trial were violated when the circuit court failed to conduct an on-the-record colloquy with him regarding his waiver of the right to proof of an element of a charge before accepting the stipulation. The circuit court granted the petition and ordered that a new trial be held. The ICA vacated the circuit court's order granting the petition. The Supreme Court vacated the ICA's judgment, holding that the circuit court did not err in concluding that the trial court's failure to conduct an on-the-record colloquy with Defendant before accepting the stipulation establishing an element of the charged offenses was plain error. View "Grindling v. State" on Justia Law

In this work injury discrimination case the Supreme Court held that in order for business necessity to constitute a valid defense to a claim of work injury discrimination, an employer must demonstrate that the employee's absence caused a business impairment that could not be reasonably alleviated by means that would not result in discrimination.The Supreme Court vacated the judgment the intermediate court of appeals' judgment on appeal and the judgment of the circuit court reversing the decision of the Director of the Hawai'i Department of Labor and Industrial Relations that the work injury discrimination in this case was contravened by Hawaii law, holding that the decision of the hearing officer that the employer in this case discriminated against the employee solely because of her work injury should have been affirmed. View "BCI Coca-Cola Bottling Co. of Los Angeles, Inc. v. Murakami" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the portion of the circuit court's judgment of conviction and sentence sentencing Defendant, holding that the circuit court plainly erred by considering Defendant's refusal to admit guilt in imposing his sentence.After a jury trial, Defendant was convicted of four counts of sexual assault in the first degree as to a minor and one count of sexual assault in the first degree as to another minor. The circuit court sentenced Defendant to a term of twenty years for each count, with terms for four of the counts to be served concurrently and the term for the remaining count to be served consecutively to the foregoing terms. The ICA affirmed. The Supreme Court reversed and remanded the case for resentencing, holding that while the arguments Defendant raised on appeal lacked merit there was clearly an indication that Defendant's sentence was likely to have been improperly influenced by his persistence in his innocence. View "State v. Barnes" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) on appeal and vacated the circuit court's order denying Appellant's oral motion to withdraw pleas in his global plea agreement to two criminal offenses, one charged in the family court and the other charged in the circuit court, holding that the circuit court should have allowed Appellant to withdraw both of his pleas.The criminal offense Appellant was charged with in the family court was legally impossible for him to have committed under the law in effect at the time of his plea. The circuit court denied Appellant's motion to withdraw his pleas in both cases and entered a sentence pursuant to the plea agreement. The ICA concluded that the circuit court should not have accepted Appellant's guilty plea to the charge in the family court case but found that Appellant's plea in the circuit court case was an otherwise valid plea. The Supreme Court held that because both of Appellant's pleas were encompassed in the global plea agreement and because the ICA correctly concluded that Appellant was entitled to withdraw his plea in the family court case, the ICA should have also held that Appellant was permitted to withdraw his plea in the circuit court case. View "State v. Guity" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals and vacated Defendant's conviction of promoting a dangerous drug in the third degree and unlawful use of drug paraphernalia, holding that Defendant's motion to suppress should have been granted because he was seized longer than was necessary for the police to conduct an investigation confirming the absence of a required tax decal.The pat-down of Defendant occurred after a police officer noticed Defendant riding a bicycle lacking a tax decal, which is required by law on all bicycles with wheels twenty inches or more in diameter. After the time necessary for the police to conduct the investigation confirming the officer's reasonable suspicion that the tax decal was missing and to issue a citation for the missing decal, a warrant check came back from dispatch indicating that Defendant had an outstanding warrant. Defendant was arrested based on the outstanding warrant, and a search incident to arrest revealed drugs and drug paraphernalia. The Supreme Court held (1) Defendant's arrest was illegal because the warrant check came back after the span of time necessary for the police to write and issue the citation; and (2) therefore, the evidence obtained as a result of the arrest was fruit of the poisonous tree. View "State v. Iona" on Justia Law