Justia Hawaii Supreme Court Opinion Summaries

The district court found Defendant guilty of operating a vehicle under the influence of an intoxicant (OVUII) in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The Intermediate Court of Appeals affirmed. The Supreme Court affirmed, holding (1) the district court properly permitted the State to amend Defendant’s Haw. Rev. Stat. 291E-61(a)(1) charge to allege mens rea; (2) insofar as the section 291E-61(a)(1) charge was properly amended and Defendant did not challenge the sufficiency of the evidence supporting his conviction for violating section 291E-61(a)(1), his conviction stands; and (3) there is no need to address Defendant’s argument that blood test results were obtained in violation of his his Miranda rights, his statutory right to counsel, and his due process rights, and Defendant’s double jeopardy conviction is irrelevant. View "State v. Tuia " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. The district court denied Defendant’s motion to suppress the breath test results and found Defendant guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Guard " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. The district court denied Defendant’s motion to suppress the breath test results and found Defendant guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Guard " on Justia Law

Gene Wong was employed by Hawaiian Airlines, Inc. (HAL) as a pilot until he retired. Upon retiring, Wong became eligible to receive medical insurance paid for by HAL. Wong claimed that, as a result of misinformation he received from the employee benefits director, he did not complete the necessary forms to enroll in Medicare Part B coverage for almost a decade. Wong filed suit against HAL, alleging negligence, negligent misrepresentation, and unfair or deceptive practice (UDAP). The circuit court granted summary judgment in favor of HAL, concluding that (1) Wong’s negligence and negligent misrepresentation claims were preempted by the Railroad Labor Act (RLA) because any duty HAL owed would be derived from HAL’s obligations to retired pilots under a collective bargaining agreement between HAL and the Airline Pilots Association, and (2) the UDAP claim failed because the deceptive act did not occur in the conduct of any trade or commerce. The Intermediate Court of Appeals affirmed. The Supreme Court vacated in part and affirmed in part, holding (1) the record in this case did not support federal preemption of Wong’s negligence and negligent misrepresentation claims because these claims were not dependent on the Pilots Agreement; and (2) summary judgment was correctly granted on Wong’s UDAP claim. View "Wong v. Hawaiian Airlines, Inc." on Justia Law

Gene Wong was employed by Hawaiian Airlines, Inc. (HAL) as a pilot until he retired. Upon retiring, Wong became eligible to receive medical insurance paid for by HAL. Wong claimed that, as a result of misinformation he received from the employee benefits director, he did not complete the necessary forms to enroll in Medicare Part B coverage for almost a decade. Wong filed suit against HAL, alleging negligence, negligent misrepresentation, and unfair or deceptive practice (UDAP). The circuit court granted summary judgment in favor of HAL, concluding that (1) Wong’s negligence and negligent misrepresentation claims were preempted by the Railroad Labor Act (RLA) because any duty HAL owed would be derived from HAL’s obligations to retired pilots under a collective bargaining agreement between HAL and the Airline Pilots Association, and (2) the UDAP claim failed because the deceptive act did not occur in the conduct of any trade or commerce. The Intermediate Court of Appeals affirmed. The Supreme Court vacated in part and affirmed in part, holding (1) the record in this case did not support federal preemption of Wong’s negligence and negligent misrepresentation claims because these claims were not dependent on the Pilots Agreement; and (2) summary judgment was correctly granted on Wong’s UDAP claim. View "Wong v. Hawaiian Airlines, Inc." on Justia Law

At a bench trial, Defendant, who was cited for excessive speeding, orally moved to suppress the citing officer’s laser gun reading on the grounds that proper foundation for the gun had not been laid. The district court denied the motion, and Defendant was subsequently found guilty. The Intermediate Appellate Court (ICA) affirmed. The Supreme Court reversed, holding that the ICA erred in concluding that the laser speed reading was admissible because the State failed to lay a proper foundation for the admission of the laser gun reading where the requirement regarding the nature and extent of the citing officer’s training was not met. View "State v. Gardner " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station, where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant moved to suppress the breath test results, arguing that he did not voluntarily consent to breath testing. The district court denied the motion and convicted Defendant of OVUII. The intermediate court of appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Bayudan " on Justia Law

After being arrested for OVUII, Defendant was taken to the police station, where he was read an implied consent form. After being informed of the sanctions for refusal, Defendant elected to take a blood test, which resulted in a blood alcohol reading above the legal limit. Defendant was ultimately convicted of OVUII. The Intermediate Court of Appeals upheld the conviction. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s blood test was the product of a warrantless search, and accordingly, Defendant’s conviction could not be upheld. View "State v. Elberson " on Justia Law

After being arrested for OVUII, Defendant was read an implied consent form. Defendant elected to take a blood test, which resulted in a blood alcohol reading above the legal limit. Defendant filed a motion to suppress the blood test results, arguing that the results were obtained in violation of the Fourth Amendment. The district court denied the motion to suppress, and Defendant was convicted of OVUII. The Supreme Court reversed, holding that, in accordance with State v. Won, the result of Defendant’s blood test was the product of a warrantless search, and accordingly, Defendant’s conviction could not be upheld. View "State v. Reilly " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII) Defendant was taken to the police station, where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant filed a motion to suppress the breath test results. The district court denied the motion to suppress. Thereafter, Defendant was convicted of OVUII. The Intermediate Court of Appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, Defendant’s OVUII conviction could not be upheld. Remanded. View "State v. Shigemura " on Justia Law