Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Hawaii
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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the judgment of the district court convicting Defendant of operating a vehicle under the influence of an intoxicant (OVUII), holding that the district court abused its discretion in denying Defendant's motion to compel. Specifically, the Supreme Court held (1) as to Defendant's speedy trial challenges, Haw. R. Penal P. 48 requires a "meaningful" commencement of trial, a trial is "meaningfully" commenced when a trial court reasonably commits its resources to the trial, and this holding applies prospectively to events occurring after publication of this decision; (2) the prosecutor in this case was not required to personally review files of the testifying police officers; and (3) the district court abused its discretion in denying Defendant's motion to compel production of a video recording showing Defendant at the police station after her arrest because the video recording was material to Defendant's defense and her request was reasonable. View "State v. Alkire" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that Defendant's privilege against self-incrimination was infringed when the circuit court permitted the jury to view a video of Defendant invoking that privilege. Defendant was charged with attempted murder in the second degree and assault in the first degree as a result of an altercation with another person during which Defendant allegedly punched and kicked that person multiple times. During trial, the State played for the jury a video of a detective interviewing Defendant that concluded with Defendant declining the detective's request that Defendant reenact the altercation. The jury convicted Defendant of attempted murder in the second degree. The ICA affirmed. The Supreme Court remanded the case for a new trial, holding that Defendant invoked his right to remain silent when he declined to participate in a reenactment of the encounter and that his right to do so was infringed when the prosecution played the police interview video before the jury at trial. View "State v. Beaudet-Close" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction of operating a vehicle under the influence of an intoxicant (OVUII), holding that admissibility of evidence under Haw. R. Evid. 608(b) involves a two-step inquiry and that the ICA erred to the extent that it suggested a trial court can consider excluded evidence in reaching judgment. At trial, defense counsel sought to impeach the credibility of one of the State's witnesses under Rule 608(b). Counsel argued that specific instances of conduct evincing the witness's untruthfulness were contained in transcripts from three other proceedings in which he was a witness for the State. The district court refused to allow defense counsel to cross-examine the witness concerning these proceedings. The ICA upheld the evidentiary rulings, noting that the district court was able to review the materials concerning the three proceedings. The Supreme Court remanded this case to the district court, holding (1) the district court erred in precluding defense counsel from cross-examining that witness as to two of the proceedings; and (2) to the extent the ICA suggested that the district court reached its judgment by taking into account evidence it had excluded, such suggestion is wrong. View "State v. Su" on Justia Law

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The Supreme Court vacated the opinion of the Intermediate Court of Appeals (ICA) vacating the circuit court's order granting Defendant's motion to suppress all evidence seized as a result of the execution of a search warrant, holding that the amount of time afforded to Defendant to respond to police officers' demand for entry was not reasonable. Police officers broke down Defendant's front door at approximately 6:15 a.m. after they knocked, announced their presence, and demanded entry four times within a twenty-five-second period. The officers had no reason to believe that Defendant was fleeing or that any evidence was being destroyed. Defendant, who was charged with drug offenses, filed a motion to suppress, arguing that the execution of the warrant violated Haw. Rev. Stat. 803-37 and Haw. Const. art. I, 7. The circuit court granted the motion to suppress. The ICA vacated their circuit court's order, concluding that Defendant was afforded a reasonable amount of time to respond to the police's demand for entry to serve the search warrant. The Supreme Court disagreed, holding (1) giving an occupant only twenty-five seconds to respond at such an early morning hour was unreasonable; and (2) there were no exigent circumstances that would have justified breaching the door earlier than would have otherwise been reasonable. View "State v. Naeole" on Justia Law

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The Supreme Court vacated the Intermediate Court of Appeals' (ICA) judgment on appeal and the circuit court's amended judgment convicting Defendant of burglary in the first degree, holding that Defendant was denied the right to effective assistance at trial. On appeal, Defendant argued that her trial counsel provided ineffective assistance by failing to adduce critical evidence impeaching the credibility of the State's key witness. The Supreme Court agreed and vacated Defendant's conviction, holding that, when viewed as a whole, the adequacy of counsel's representation was not within the range of competence demanded of counsel in criminal cases. View "State v. Salavea" on Justia Law

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The Supreme Court affirmed Defendant's conviction and sentence for murder in the second degree, holding that third party culpability evidence was erroneously excluded, but the error was harmless beyond a reasonable doubt. On appeal, Defendant asserted (1) the trial court abused its discretion by excluding evidence tending to show that a third party committed the offense; (2) the trial court erred by admitting into evidence a confession letter allegedly written by Defendant because of its late disclosure to the defense; and (3) DNA results showing Defendant's presence at the crime scene were improperly admitted at trial. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admitting the confession letter at trial because the timing of the State's disclosure did not require exclusion; (2) a sufficient foundation to admit the results of the DNA analyses was established to allow their admission into evidence; and (3) evidence of the third party's culpability was improperly excluded, but the exclusion was harmless beyond a reasonable doubt. View "State v. Texeira" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the judgment of the circuit court convicting Defendant of reckless endangering in the second degree, holding that the circuit court erred by excluding Defendant from presenting third-party culpability evidence at trial. In precluding Defendant from presenting third-party culpability evidence the circuit court determined that the evidence failed to establish a "legitimate tendency" that the third party committed the crime. The Supreme Court vacated Defendant's conviction, holding (1) admissibility of third-party culpability evidence is properly governed by Haw. R. Evid. 401 and 403, without having also to satisfy a legitimate tendency test; (2) the circuit court erred in precluding the defense from adducing third-party culpability evidence that another person assaulted the complaining witness; and (3) the circuit court and the ICA improperly weighed the third-party culpability evidence offered by Defendant. View "State v. Kato" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the judgment of the circuit court convicting Defendant of sexual assault in the first degree and sexual assault in the third degree, holding that Defendant's confession should not have been admitted against him at trial. Defendant gave his confession during a custodial interrogation. At issue on appeal was whether Defendant's constitutional right against self-incrimination was violated by the admission of his confession. The ICA affirmed the circuit court's ruling that the confession was voluntarily given. The Supreme Court reversed, holding (1) due to law enforcement's coercive tactics and deception about incontrovertible physical evidence Defendant's confession was involuntary under the totality of the circumstances; and (2) the admission of Defendant's statement was not harmless error. View "State v. Baker" on Justia Law

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The Supreme Court reversed Defendant's conviction of assault against a law enforcement officer in the second degree, holding that the record did not reflect an on-the-record exchange sufficient to constitute the true colloquy required to establish a knowing and intelligent waiver of Defendant's constitutional right to a jury trial. Defendant was convicted after a bench trial. On appeal, Defendant argued that the district court reversibly erred in failing to obtain a valid on-the-record waiver of his constitutional right to a jury trial. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgments of the ICA and the district court, holding that, under the totality of the circumstances, the record did not reflect an on-the-record exchange sufficient to constitute the true colloquy required to establish a knowing and intelligent waiver of Defendant's constitutional right to a jury trial. View "State v. Ernes" on Justia Law

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The Supreme Court vacated the intermediate court of appeals' (ICA) judgment on appeal and the circuit court's judgment of conviction and sentence, holding that the circuit court erred in admitting a portion of the complaining witness's testimony and that the error was not harmless beyond a reasonable doubt. Defendant was indicted for one count of sexual assault in the first degree and one count of sexual assault in the third degree. The jury found Defendant guilty on both counts. The ICA affirmed. On appeal, Defendant argued that a portion of the complaining witness's (CW) testimony was not properly admitted for the purpose of bolstering the credibility of the CW's account of the incident. The Supreme Court agreed, holding that the cited testimony was not relevant to the witness's credibility, and the erroneous admission of the testimony was highly prejudicial to the defense. View "State v. Lora" on Justia Law