Justia Hawaii Supreme Court Opinion Summaries

The circuit court excluded three statements that Defendant made to the police, concluding that the first and second statements were unlawfully elicited from Defendant because they were obtained prior to the police apprising Defendant of his Miranda right. The court concluded that the third statement, obtained from Defendant when he invoked his right to counsel while being given Miranda warnings, was a product of the two earlier illegally obtained statements. The intermediate court of appeals (ICA) vacated the circuit court’s ruling as to the second and third statements. The Supreme Court vacated the ICA’s judgment on appeal and affirmed the circuit court’s order suppressing the statements, holding that the second statement was inadmissible into evidence because it was the product of pre-Miranda custodial interrogation and that the third statement was the fruit of the first and second statements. View "State v. Trinque" on Justia Law

Defendant and his codefendant were charged with methamphetamine trafficking in the second degree. The Supreme Court reversed Defendant’s conviction, holding that the circuit court erred in instructing the jury on the offense of second-degree methamphetamine trafficking, and the error was not harmless beyond a reasonable doubt. Specifically, the court held that the jury instruction on second-degree methamphetamine trafficking could have been reasonably understood as relieving the State of its burden to prove that the relevant state of mind applies to the “attendant circumstances” element of the charged offense. The court remanded the case to the circuit court for further proceedings. View "State v. Bovee" on Justia Law

The Supreme Court vacated the judgment of the District Court of the Fifth Circuit finding Defendant guilty of simple trespass and harassment, holding that the record on appeal did not indicate a valid waiver of counsel. Defendant elected to proceed pro se at trial. On appeal, the Supreme Court engaged in a plain error to review to determine whether Defendant’s constitutional right to counsel may have been affected during the proceedings below. The court held that, based on the totality of the circumstances in this case, there was no valid waiver of counsel under the test set forth in State v. Phua. View "State v. Erum " on Justia Law

Court had discretion to permit government-condemnor to withdraw a portion of deposit of estimated just compensation.Three parcels of privately-owned property were condemned for a public park. In the owner’s appeal, the Supreme Court of Hawaii held that the presence or lack of physical unity is not dispositive of whether a condemnee is entitled to severance damages. A deposit of estimated just compensation does not become conditional, and blight of summons damages do not begin to accrue, when a condemning authority objects to a condemnee’s motion to withdraw funds based on the fact that the condemnee’s entitlement to such funds is unclear. The court in an eminent domain proceeding has discretion to permit a governmental entity to withdraw a portion of a deposit of estimated just compensation when the deposit has not been disbursed to the landowner, the government acted in good faith in seeking to adjust the estimate to accurately reflect the value of the property on the date of the summons, and the adjustment will not impair the substantial rights of any party in interest. View "County of Kauai v. Hanalei River Holdings Limited" on Justia Law

The Supreme Court remanded this divorce case to the family court, holding that the family court erred in failing to identify equitable considerations that could have justified deviating from the partnership model when the divorce resulted in significant financial disparity between Husband and Wife. The family court awarded virtually all of the spouses’ property to Husband, a seventy-one-year-old retired musician and trust fund beneficiary, who was also receiving court-ordered spousal support from Wife, a fifty-six-year-old emergency room doctor. The Supreme Court further held that the family court erred by not explaining why it rejected Wife’s request to deviate from the partnership model. View "Selvage v. Moire" on Justia Law

The Supreme Court vacated Defendant’s conviction for operating or assuming actual physical control of a vehicle with .08 or more grams of alcohol per 210 liters of breath, holding that the district court erred in admitting two sworn statements by an Intoxilyzer supervisor to prove that the Intoxilyzer used to test Defendant’s breath alcohol content was in proper working order. The court held that the statements were improperly admitted under the public records exception because they contained an evaluative opinion that did not constitute a “matter observed” within the meaning of Haw. R. Evid. 803(b)(8). Therefore, the State failed to lay a sufficient foundation that the Intoxilyzer was in proper working order when the breath test was administered to Defendant. View "State v. Davis" on Justia Law

An anticipatory search warrant must, on its face, identify the triggering condition on the face of the warrant to be valid.Petitioners were charged with drug offenses based on evidence seized in a search conducted pursuant to an anticipatory search warrant. The circuit court denied Petitioners’ motion to suppress the evidence, and the intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's judgment and the circuit court’s denial of Petitioners’ motion to suppress, holding that, in light of this opinion, the search warrant was unlawful. The court remanded the case to the circuit court for further proceedings. View "State v. Curtis" on Justia Law

In this summary disposition order, the Supreme Court affirmed Defendant’s conviction for resisting arrest but reversed Defendant’s conviction for burglary in the second degree. The court held that the intermediate court of appeals erred in affirming the circuit court’s denial of Defendant’s motion of acquittal as to the burglary count. Specifically, pursuant to the Supreme Court’s decision in State v. King, 386 P.3d 886 (2016), Defendant’s contravention of a written trespass warning did not constitute an unlawful entry for the purposes of burglary in the second degree. Accordingly, a reasonable juror could not have concluded, based on the evidence, that Defendant was guilty of burglary in the second degree. View "State v. Collins " on Justia Law

Defendant was convicted of one count of methamphetamine trafficking in the first degree and two counts of prohibited acts related to drug paraphernalia. The circuit court imposed a mandatory minimum term of thirteen years and four months on Defendant’s twenty-year sentence on the methamphetamine trafficking charge because Defendant had a prior conviction for methamphetamine trafficking. The Supreme Court remanded Defendant’s case to the circuit court for a new trial, holding that the circuit court erred in construing Defendant’s prior conviction as an element of the offense, thus unnecessarily subjecting Defendant to potential prejudice due to the jurors learning of his prior felony conviction. View "State v. Wagner" on Justia Law

John Hasircoglu was an employee of a subcontractor to FOPCO, Inc., the general contractor on a tunnel construction project on Molokai. In response to a request by the State, FOPCO identified Donald Clark and Michael Estes, neither of whom were FOPCO employees, as “project superintendent and key personnel.” The circuit court granted summary judgment in favor of FOPCO on all claims. The intermediate court of appeals affirmed on the grounds that Estes and Clark were not agents of FOPCO, and therefore, FOPCO could not be held vicariously liable for their alleged negligence. The Supreme Court vacated in part and otherwise affirmed, holding (1) there existed a genuine issue of material fact as to whether there was an agency relationship between FOPCO and Estes and/or Clark based on actual express or implied authority; and (2) summary judgment was proper as to Plaintiffs’ remaining claims. View "Hasircoglu v. FOPCO, Inc." on Justia Law