Justia Hawaii Supreme Court Opinion Summaries

Petitioner Less Schnabel allegedly caused the death of decedent by one punch. After a jury trial, Petitioner was found guilty of manslaughter and sentenced to twenty years of imprisonment. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment of the ICA, holding (1) the ICA gravely erred in affirming the ruling of the circuit court that the State would be allowed to introduce evidence from the prior juvenile proceedings of Petitioner if Petitioner testified on cross-examination in the instant case that he did not know a single punch could cause the death of a person; and (2) the statement of the deputy prosecuting attorney to the jury during closing arguments not to "get too caught up in the mumbo jumbo of all the words [of the jury instructions,]" among other statements, infringed on Petitioner's right to have the case against him proven beyond a reasonable doubt. Remanded. View "State v. Schnabel" on Justia Law

Defendant Lloyd Pratt received three citations when he was found residing in a closed area of a state park. Pratt filed a motion to dismiss the charges, asserting as a defense that his activities were constitutionally-protected native Hawaiian practices, and citing State v. Hanapi, which defined the scope in the criminal context of the legal privilege for native Hawaiians to engage in customary or traditional native Hawaiian practices when such practices conflict with State statute or regulations. The district court denied the motion, held trial, and found Pratt guilty on all three charges. The intermediate court of appeals (ICA) affirmed. The Supreme Court granted certiorari to clarify the law surrounding the assertion of native Hawaiian rights as a defense in criminal cases. The Court affirmed, holding (1) the courts below did not err in utilizing a balancing test in this case; (2) in balancing interests, the court must consider the totality of the circumstances; and (3) under the totality of the circumstances test, Pratt's convictions must be affirmed. View "State v. Pratt" on Justia Law

Petitioner Patrick Ho was convicted of first degree sexual assault and third degree sexual assault. Petitioner appealed, arguing (1) the circuit court's refusal to disqualify two jurors who were sexually assaulted as teenagers compelled him to use two of his three peremptories to remove the jurors from the jury panel, and (2) the court erroneously removed two other jurors for cause at Respondent's request after Petitioner exercised all of his peremptories, based on identical grounds urged by the State before the parties exercised their peremptory challenges. The Supreme Court vacated the judgment of conviction and sentence, holding that under the circumstances here, the circuit court plainly erred when during jury selection it removed two jurors for cause on the motion of the State after the jury panel already had been passed for cause and Petitioner and the State had already exhausted their peremptory challenges. Remanded for a new trial. View "State v. Ho" on Justia Law

In this case the Supreme Court was presented with the question of whether the political question doctrine barred Hawaiian Homes Commission Act (HHCA) beneficiaries from using the Hawaiian Constitution's "sufficient sums" provision to demand more legislative funding of the Department of Hawaiian Home Lands (DHHL) when that provision provided no guidance as to how quickly homesteads must be developed. The Supreme Court held (1) judicial determination of "sufficient sums" as to the purpose of DHHL's administrative and operating expenses is not barred as a nonjusticiable political question, and the intermediate court of appeals (ICA) did not err in so holding; but (2) the political question bars judicial determination of what would constitute "sufficient sums" for the purposes of (a) development of home, agriculture, farm and ranch lots, (b) home, agriculture, aquaculture, farm and ranch loans, and (c) rehabilitation projects, and the ICA erred in concluding otherwise. View "Nelson v. Hawaiian Homes Comm'n" on Justia Law

This case arose from a fatal car accident that occurred on a county highway, which resulted in the death of Shawn Kaikala. Petitioners, several individuals related to Kaikala, filed a civil complaint against the State, asserting claims for negligence and wrongful death. The circuit court entered judgment in favor of the State. Petitioners filed a notice of appeal after the circuit court extended the deadline. The intermediate court of appeals (ICA) concluded (1) absent a finding of "good cause," it was improper for the circuit court to grant the deadline extension, and (2) therefore, the ICA did not have jurisdiction to hear the appeal because Petitioners' notice of appeal was untimely. The Supreme Court vacated the ICA's dismissal of Petitioners' appeal, holding that based upon the specific, unique factual circumstances in this case, the ICA erred by concluding that it did not have jurisdiction to hear Petitioners' appeal. Remanded for consideration on the merits. View "Cabral v. State" on Justia Law

Petitioner Michael Tierney was charged with promoting a detrimental drug in the third degree. The trial court determined that Petitioner's fitness to proceed to trial was at issue and ordered a one person panel to examine Petitioner. Petitioner refused to cooperate with the examination. The trial court proceeded to trial without the examiner's opinion and found Petitioner guilty of the charge. The intermediate court of appeals (ICA) affirmed. The Supreme Court reversed, holding (1) when a court orders an examination to determine whether a defendant is fit to proceed to trial pursuant to Haw. Rev. Stat. 704-404(1) and the defendant refuses to cooperate with the examiner, the examiner must produce a report of the examination that expressly states whether such unwillingness of defendant was the result of physical or mental disease, if possible; (2) if it is not possible for the examiner to make that determination, the examiner must expressly state as much; and (3) because the examiner in this case did not state in his report whether Petitioner was fit to proceed or state that it was impossible to make that determination, the district court abused its opinion in proceeding to trial without the examiner's opinion. View "State v. Tierney" on Justia Law

This case arose from the 2008 application of the Honolulu Department of Environmental Services (DES) for a special use permit (SUP) to expand an existing sanitary landfill. The Land Use Commission (LUC) approved the SUP subject to, inter alia, a condition prohibiting the landfill from accepting municipal solid waste after July 31, 2012. The validity of this condition was the sole issue raised by DES on appeal. The Supreme Court vacated the circuit court's judgment affirming the LUC's approval of the SUP, holding (1) the condition was inconsistent with the evidence shown in the record and was not supported by substantial evidence; and (2) because the LUC's approval of the SUP was expressly given subject to the LUC's imposition of the condition, the court's judgment must be vacated. Remanded. View "Dep't of Envtl. Servs. v. Land Use Comm'n" on Justia Law

Petitioner Kevin Yamahata was adjudged guilty by the district court 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 appeal (ICA) affirmed. Yamahata appealed, contending that the ICA gravely erred in holding that mens rea need not be alleged in either a section 291E-61(a)(1) or (a)(3) charge pursuant to State v. Nesmith. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Yamahata's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Yamahata did not challenge the sufficiency of the evidence as to that basis, his conviction still stood. View "State v. Yamashita " on Justia Law

Petitioner James Flynn was found guilty of operating a vehicle under the influence of an intoxicant in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) pursuant to State v. Nesmith, the ICA erred by concluding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and without such allegation, Flynn's section 291E-61(a)(1) charge was fatally deficient; but (2) insofar as Flynn's conviction under the alternative charge based upon subsection 291E-61(a)(3) was sufficient, and insofar as Flynn did not challenge the sufficiency of the evidence as to that basis, his conviction under subsection (a)(3) stood. View "State v. Flynn " on Justia Law

Petitioner Tommy Bullard was convicted of operating a vehicle under the influence of an intoxicant (OVUII) in violation of Haw. Rev. Stat. 291E-61(a)(1). The intermediate court of appeals (ICA) affirmed. The Supreme Court accepted Bullard's application for writ of certiorari and vacated the judgment of the ICA, holding (1) pursuant to State v. Nesmith, which holds that an OVUII charge under section 291E-61(a)(1) must allege mens rea, the ICA erred by concluding that mens rea need not be alleged in a section 291E-61(a)(1) charge; and (2) without such allegation, Bullard's charge was fatally deficient. Remanded to the district court with instructions to dismiss without prejudice. View "State v. Bullard " on Justia Law