Justia Hawaii Supreme Court Opinion Summaries

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

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