Justia Criminal Law Opinion Summaries

After a bench trial, Petitioner was convicted of abuse of a family or household member. On appeal, Petitioner argued that the family court did not ensure that he had “fully” waived his right to a jury trial. The intermediate court of appeals (ICA) affirmed, concluding that under the totality of the circumstances, Petitioner had validly waived his right to a jury trial. The Supreme Court vacated the ICA’s judgment and the family court’s judgment, holding that the family court failed to ensure that Petitioner’s waiver of his right to a jury trial was voluntary. Remanded for a new trial. View "State v. Baker" on Justia Law

Defendant was tried for attempted murder in the second degree. During the proceedings, Defendant expressed his desire to proceed pro se. The circuit court determined that Defendant waived his right to counsel, and Defendant was pro se for the rest of the trial. After the jury returned a guilty verdict, Defendant’s standby counsel filed a motion to withdraw as standby counsel and that substitute counsel be appointed to assist Defendant post-trial and on appeal. The circuit court allowed standby counsel to withdraw but did not appoint substitute counsel for Defendant’s post-verdict motions or for sentencing. The Supreme Court remanded the case, holding that the circuit court erred (1) by not appointing substitute counsel for Defendant’s post-verdict motions because post-verdict proceedings are critical stages in the prosecution; and (2) by not appointing Defendant substitute counsel for sentencing. View "State v. Pitts" on Justia Law

Petitioner was convicted of one count of operating a vehicle under the influence of an intoxicant (Count I) and one count of accidents involving damage to vehicle or property (Count II). The intermediate court of appeals (ICA) affirmed. Petitioner sought review of the judgment of the ICA, raising a challenge to the sufficient of the complaint with respect to Count II. Specifically, Petitioner claimed that Count II failed to charge a requisite state of mind. The Supreme Court vacated the judgment of the lower courts, holding that inasmuch as Count II of the complaint against Petitioner failed to allege the requisite state of mind, it must be dismissed. View "State v. Tongg " on Justia Law

Petitioner was convicted of prostitution. The intermediate court of appeals (ICA) affirmed. The ICA sua sponte raised the issue of whether the charge was deficient for failing to allege the requisite mens rea, which was an essential fact of the offense of prostitution. The ICA, inter alia, held that Petitioner “waived any sufficiency to the charge for failure to allege a mens rea” by not objecting on this basis and by not asserting the claim on appeal. The Supreme Court vacated the judgments of the lower courts, holding that, inasmuch as the complaint against Petitioner failed to allege the requisite state of mind for the offense of prostitution, the complaint must be dismissed. View "State v. Shyanguya " on Justia Law

Petitioner was convicted of excessive speeding. The intermediate court of appeals (ICA) affirmed. Petitioner sought review of the judgment of the ICA, challenging for the first time the sufficiency of the charge on the grounds that the amended complaint did not allege the required state of mind to prove the charge of excessive speeding. The Supreme Court vacated the judgments of the lower courts, holding that, inasmuch as the amended complaint against Petitioner failed to allege the requisite state of mind, which was an essential fact of the offense of excessive speeding, the amended complaint must be dismissed. View "State v. Pierce " on Justia Law

Defendant was convicted of murder in the second degree and several other charges. At issue before the Supreme Court was whether the circuit court plainly erred in excluding expert testimony on cocaine use where the defense expert was prepared to testify that, to a reasonable degree of scientific probability, the victim was under the influence of cocaine at the time of the shooting. The Supreme Court vacated Defendant’s convictions for second-degree murder and carrying or use of a firearm while engaged in the commission of a separate felony, holding that the circuit court committed reversible error by excluding the testimony on the grounds that the testimony must be offered to a reasonable degree of scientific certainty. Remanded. View "State v. Deleon" on Justia Law

The district court adjudged Petitioner guilty of operating a vehicle under the influence of an intoxicant (OVUII). The intermediate court of appeals (ICA) affirmed. The Supreme Court reversed, holding (1) the district court did not abuse its discretion in continuing the trial for a fourth day because it had already determined that the trial would not be completed on the third day; but (2) the OVUII charge was deficient by failing to state the offense of OVUII where it did not allege the attendant circumstance that Defendant operated his vehicle on a public roadway. Remanded. View "State v. Akitake " on Justia Law

Defendant was charged with electronic enticement in the first degree (Count 1) and promoting child abuse in the third degree (Count 2). The charges were severed. The State then proceeded to trial on Count 1 and appealed the circuit court’s suppression order as it related to count 2. In relevant part, the court suppressed a statement made by Defendant after he was arrested and evidence seized from Defendant’s residence pursuant to a misdated search warrant. After a jury trial, Defendant was convicted of electronic enticement. Both parties appealed. The intermediate court of appeals (ICA) affirmed Defendant’s conviction and vacated the suppression order. The Supreme Court affirmed in part and vacated in part the ICA’s judgment, holding (1) the circuit court did not err in affirming Defendant’s conviction for electronic enticement; (2) suppression of Defendant’s statement was proper where law enforcement officers failed to obtain a voluntary waiver of Defendant’s Miranda rights; and (3) the circuit court erred in suppressing evidence obtained pursuant to the search warrant. Remanded. View "State v. McKnight" on Justia Law

The State charged Defendant with harassment. Before trial commenced, the district court granted Defendant’s motion to dismiss the complaint on the ground that disjunctive wording in the complaint made it difficult to prepare a defense. The intermediate court of appeals affirmed, concluding that because the complaint charged two forms of non-synonymous conduct disjunctively, the charge did not provide Defendant with adequate notice. The Supreme Court reversed, holding (1) when charging a defendant under a single subsection of a statute, the charge may be worded disjunctively in the language of the statute as long as the acts charged are reasonably related so that the charge provides sufficient notice to the defendant; and (2) the complaint in this case met due process requirements regardless of whether the disjunctively charged acts were synonymous or non-synonymous. View "State v. Codiamat" on Justia Law

The State indicted Petitioner on kidnapping and assault in the second degree. A jury found Petitioner guilty of kidnapping and of the lesser included offense of assault in the third degree. Petitioner filed a motion for judgment of acquittal, arguing (1) the State failed to prove venue was proper in this case; and (2) the Class A felony kidnapping should be reduced to Class B kidnapping because the complainant did not sustain serious or substantial injury as shown by the jury acquitting Petitioner of assault in the second degree. The trial court denied the motion. The Supreme Court affirmed the convictions, holding (1) because several witnesses testified that the offense occurred on the island of Oahu, there was sufficient evidence to demonstrate the first judicial circuit was the correct venue; and (2) while the State must prove beyond a reasonable doubt that substantial bodily injury was caused by Defendant in order to disprove the mitigating defense that reduces the offense of kidnapping from a Class A felony to a Class B felony, the State disproved one of the three elements of the Class B mitigating defense beyond a reasonable doubt to establish that Defendant was not entitled to the defense. View "State v. Bailey " on Justia Law