Justia Hawaii Supreme Court Opinion Summaries

Petitioner Emilio Soria was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1). The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's judgment, holding that pursuant to State v. Nesmith, which states that mens rea must be alleged in a section 291E-61(a)(1) charge in order to provide fair notice of the nature and cause of the accusation, the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge. Therefore, Shinsato's section 291E-61(a)(1) charge was deficient for failing to allege mens rea. Remanded to the district court with instructions to dismiss the complaint without prejudice. View "State v. Soria " on Justia Law

Petitioner Rew Shinsato was adjudged guilty by the district court 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) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Shinsato'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 Shinsato did not challenge the sufficiency of the evidence as to that basis, Shinsato's conviction still stood. View "State v. Shinsato " on Justia Law

Petitioner Alejandro Padilla was adjudged guilty by the district court 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) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Padilla'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 Padilla did not challenge the sufficiency of the evidence as to that basis, Padilla's conviction still stood. View "State v. Padilla " on Justia Law

Petitioner William Daniels was adjudged 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) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Daniels' 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 Daniels did not challenge the sufficiency of the evidence as to that basis, Daniels' conviction still stood. View "State v. Daniels " on Justia Law

Landowners brought this lawsuit against their neighbor, seeking compensation for property damage caused by the neighbor, and seeking a determination of access and water rights. The application before the Supreme Court, however, raised questions concerning procedural aspects of the hearings before the trial court and of the appeal to the intermediate court of appeals (ICA). The first question concerned pleading standards of appellate briefs, and the remaining questions addressed the trial court's determination of which parties must participate in a lawsuit, and the procedure an appellate court should follow when reviewing that determination. The Court reversed the decision of the ICA and reinstated the trial court's order, holding (1) the ICA did not err in reviewing the defendants' points of error on appeal; but (2) the ICA erred in vacating the trial court's final judgment. View "Marvin v. Pflueger" on Justia Law

Kevin Nesmith and Chris Yamamoto were each charged with operating a vehicle under the influence of an intoxicant (OVUII) pursuant to Haw. Rev. Stat. 291E-61(a)(1) and/or (a)(3). The trial court found Nesmith and Yamamoto guilty as charged. Nesmith and Yamamoto appealed, alleging that the complaints were legally deficient for having failed to allege mens rea. The intermediate court of appeals (ICA) affirmed, holding that mens rea need not be alleged in a complaint charging crimes under sections 291E-6a(a)(1) and/or (a)(3). The Supreme Court consolidated the cases and held (1) pursuant to State v. Wheeler, a charge of OVUII under section 291E-61(a)(1) must allege the requisite mens rea; (2) an OVUII charge under section 291E-61(a)(3) is an absolute liability offense for which mens rea need not be alleged or proven; (3) the ICA erred by relying on general intent cases to hold that mens rea may be inferred from the allegations in a section 291E-61(a)(1) OVUII charge; and (4) the State v. Nesmith majority erred by extending Haw. Rev. Stat. 806-28 to the district courts. View "State v. Yamamoto" on Justia Law

Defendant Pulumata'ala Eli was convicted of attempted manslaughter. Defendant appealed, arguing that the trial court erred by failing to suppress a statement Defendant made to a detective in violation of his rights under Miranda v. Arizona. The Supreme Court vacated the circuit court's judgment of conviction and sentence, holding (1) the police practice of inviting an arrestee to make a statement and to give his or her "side of the story" or similar entreaties in a "pre-interview" before Miranda warnings are given violates the defendant's constitutional right against self-incrimination and right to due process; and (2) under the circumstances of this case, the Mirandized statement offered into evidence at trial resulted from the exploitation of the said pre-interview practice, and the Miranda warnings subsequently given did not remove the taint of such practice. Remanded for a new trial. View "State v. Eli" on Justia Law

Kevin Nesmith and Chris Yamamoto were each charged with operating a vehicle under the influence of an intoxicant (OVUII) pursuant to Haw. Rev. Stat. 291E-61(a)(1) and/or (a)(3). The trial court found Nesmith and Yamamoto guilty as charged. Nesmith and Yamamoto appealed, alleging that the complaints were legally deficient for having failed to allege mens rea. The intermediate court of appeals (ICA) affirmed, holding that mens rea need not be alleged in a complaint charging crimes under sections 291E-6a(a)(1) and/or (a)(3). The Supreme Court consolidated the cases and held (1) pursuant to State v. Wheeler, a charge of OVUII under section 291E-61(a)(1) must allege the requisite mens rea; (2) an OVUII charge under section 291E-61(a)(3) is an absolute liability offense for which mens rea need not be alleged or proven; (3) the ICA erred by relying on general intent cases to hold that mens rea may be inferred from the allegations in a section 291E-61(a)(1) OVUII charge; and (4) the State v. Nesmith majority erred by extending Haw. Rev. Stat. 806-28 to the district courts. View "State v. Nesmith" on Justia Law

The circuit court found Samuel Walker guilty of three offenses, including Count I, habitually operating a vehicle under the influence of an intoxicant (HOVUII). The intermediate court of appeals (ICA) vacated the circuit court's judgment and remanded Walker's case with instructions to dismiss Count I without prejudice, holding that Count I of the felony information failed to allege an essential element, an attendant circumstance, of the charge of HOVUII. The Supreme Court affirmed, holding (1) an appellate court's remand for entry of judgment of conviction and resentencing for a lesser-included offense must be based on a jurisdictionally valid lesser-included charge; and (2) under this holding, Walker's HOVUII charge did not adequately allege the lesser-included offense of OVUII as a first offender because his charge failed to allege an essential element, specifically, the attendant circumstance that he operated a vehicle on a public road, way, street, or highway. View "State v. Walker" on Justia Law

Jason Kiese was found guilty by the family court of one count of harassment. After the trial, the family court denied Kiese's motion to stay his sentence pending appeal. The intermediate court of appeals (ICA) affirmed the judgment of conviction and concluded that the family court's denial of Kiese's stay was erroneous but moot. The Supreme Court upheld the conviction and, because Kiese had already served his probationary sentence, affirmed the ICA's judgment on appeal, holding (1) the ICA correctly held that there was sufficient evidence to sustain Kiese's harassment conviction; (2) the ICA erred in not addressing the family court's failure to stay Keise's sentence pending appeal based on the mootness doctrine because the public interest exception to the mootness doctrine applied; and (3) the family court erred by denying Kiese a stay of his petty misdemeanor sentence pending appeal because Kiese, as a petty misdemeanant on bail, was entitled to a continuance of bail as a matter of right pending appellate review, and the family court was without jurisdiction to execute Kiese's sentence. View "State v. Kiese" on Justia Law