Justia Criminal Law Opinion Summaries

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) determining that the State's complaint was sufficient and sustaining that the State's "golden rule" objection, holding that the complaint was defective and that the "golden rule" argument did not apply.Defendant was convicted of obstructing. The ICA vacated the conviction and remanded for a new trial, holding that there was an error in the jury instructions. On certiorari, Defendant asked the Supreme Court to determine whether the ICA erred in determining that the State's complaint was sufficient despite its failure to define the statutory term "obstructs" and whether the ICA erred in analyzing a golden rule objection made by the State during Defendant's closing argument. The Supreme Court remanded the case to the circuit court to dismiss the obstructing charge, holding (1) by omitting an essential element of the offense of obstructing, the complaint was insufficient; and (2) while the ICA correctly concluded that the circuit court erred in sustaining the State's objection to defense counsel's closing argument, it incorrectly analyzed whether that error was harmless. View "State v. Kauhane" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) affirming the circuit court's order denying Petitioner's petition to vacate, set aside, or correct judgment or to release Petitioner from custody, holding that Petitioner's Haw. R. Pen. P. 40 petition stated a colorable claim that the Hawai'i Paroling Authority (HPA) violated his due process rights.Petitioner pleaded guilty to manslaughter and firearms offenses. In his Rule 40 petition, Petitioner argued that the HPA arbitrarily and capriciously determined that he was a Level III offender for purposes of calculating his minimum term of imprisonment on his manslaughter conviction. The circuit court denied the petition without holding a hearing. The ICA affirmed. The Supreme Court vacated the judgment in part and remanded the case, holding (1) Petitioner raised a colorable claim that the HPA arbitrarily and capriciously maintained Petitioner's level of punishment at Level III on the manslaughter conviction; and (2) Petitioner raised a colorable claim that the circuit court provided inadequate reasons for imposing consecutive sentences. View "Lewi v. State" on Justia Law

The Supreme Court vacated Defendant's conviction and remanded the case for further proceedings, holding that the trial court erred in determining that Defendant's confession was voluntarily made despite an interrogating officer informing him, untruthfully, that he did not pass a polygraph test, holding the deliberate falsehood regarding the polygraph results impermissibly tainted Defendant's confession.The trial court admitted Defendant's confession into evidence over defense objection. The court further ruled that during Defendant's trial testimony, when discussing the circumstances of his confession, could not mention the words "polygraph" or "test" or that the interrogating officer gave him inaccurate test results before his confession was elicited. The Supreme Court vacated the conviction, holding (1) the admission of Defendant's confession was not harmless error; (2) the exclusion of evidence of the circumstances surrounding the eliciting of Defendant's confession severely compromised Defendant's constitutional right to a fair trial and to present a complete defense; and (3) the court's jury instruction that defined an element of the charged offense contained a misstatement of law and was ambiguous and incomplete. View "State v. Matsumoto" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the judgment of the district court accepting Defendant's pleas of no contest to open lewdness and disorderly conduct, holding that the trial judge erred in denying Defendant's oral motion to defer the acceptance of her no contest plea (motion for DANC).The State and Defendant reached an agreement where Defendant would plead no contest to the charges against her, the State would recommend five days of jail time and would not object to a subsequent motion for DANC, provided that Defendant be placed on unsupervised probation for six months. After Defendant made an oral motion for DANC the district court denied the motion on the basis that Defendant did not wish to stay in Hawaii during the six-month probation period. The ICA affirmed. The Supreme Court vacated and remanded, holding that the district court abused its discretion in denying Defendant's motion for DANC where defense counsel stated that Defendant would be willing to return to Hawaii and the court did not specifically consider the factors described in Haw. Rev. Stat. 853-1. View "State v. Phillips " on Justia Law

In this case concerning the admissibility of a suggestive eyewitness or show-up identification, the Supreme Court set forth new rules and because the holdings apply only prospectively to events occurring after publication of this decision, the Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction.Defendant was charged with one count of burglary in the first degree. Before trial, Defendant filed a motion to suppress a witness's show-up identification. The State stipulated that the procedure employed by the police department was impermissibly suggestive, but the circuit court nonetheless denied the motion, finding the witness's identification sufficiently reliable. The jury then found Defendant guilty as charged. The ICA affirmed. The Supreme Court affirmed but set forth new rules in this opinion regarding whether an eyewitness identification procured through an impermissibly suggestive procedure is nonetheless sufficiently reliable under the totality of the circumstances to be admitted in evidence. View "State v. Kaneaikala" on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) reversing Defendant's conviction of harassment and affirmed the district court's judgment, holding that Defendant's harassment conviction was supported by substantial evidence.Defendant was charged with harassment stemming from statements he made to a complaining witness (CW), a seventeen-year-old female. CW testified that Defendant made sexually explicit comments to her that made her feel uncomfortable, unsafe, and scared. CW, however, did not explicitly state that she believed Defendant intended to cause her bodily injury, an essential element of the offense charged. The district court determined that Defendant's statements caused CW to believe that Defendant intended to have non-consensual sexual contact with her. The ICA reversed, concluding that there was no evidence that CW reasonably believed Defendant intended to cause her bodily injury. The Supreme Court reversed, holding (1) both elements of harassment and the requisite state of mind were supported by evidence adduced at trial; and (2) Defendant's constitutional challenges were without merit. View "State v. Calaycay" on Justia Law

The Supreme Court reversed Defendant's conviction for assault in the second degree, holding that Defendant's constitutional right to confrontation was violated when the circuit court refused to allow cross-examination of the complaining witness on topics relevant to her bias, interest, or motive for testifying against Defendant, and the error was not harmless beyond a reasonable doubt.On appeal, Defendant argued that the trial court erred in refusing to allow him to cross-examine the complaining witness regarding her pending misdemeanor assault charge arising from the same incident for which Defendant was charged, as well as her probation status resulting from a separate assault charge. The Supreme Court agreed, holding that Defendant's constitutional right to confront witnesses was violated, and because the exclusion of the information might have contributed to the jury's decision to convict, the violation of Defendant's right to confrontation was not harmless beyond a reasonable doubt. View "State v. Brown" on Justia Law

The Supreme Court vacated the decision of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and probation sentence in favor of the State and vacated the circuit court's judgment of conviction and probation sentence, holding that the ICA erred.In 2000, Defendant was convicted and sentenced for charges of sex assault in the second and third degree. Defendant was sentenced to five years of probation and ordered both to complete sex offender treatment and to register as a sex offender. In 2011, Defendant's probation was revoked, and he was resentenced to ten years' confinement. Defendant's sentence for the sex assault convictions expired in 2010. In 2016, Defendant was adjudicated guilty of two counts of failure to comply with covered offender registration requirements. The circuit court sentenced Defendant to a four-year term of probation and ordered, as a special condition of probation, that Defendant participate in a sex offender treatment program. The Supreme Court remanded the matter to the circuit court for resentencing, holding that the ICA erred in affirming based, in part, on its unsubstantiated understanding that Defendant did not previously complete the sex offender treatment program, as ordered. View "State v. Young " on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) vacating the circuit court's order granting Defendant's motion to suppress, holding that the police lacked reasonable suspicion to seize Defendant while he was lying next to the beach in Waikiki.Defendant was approached by police officers while he was lying on a concrete slab adjacent to an apartment complex on Waikiki beach. After an officer asked Defendant to provide his identification and Defendant provided a Veterans Affairs medical card to the officer, the officer noticed Defendant was grasping something in his backpack. An officer pulled the bag from Defendant, and a collapsible baton fell out of the backpack. Defendant grabbed the baton and held it up as if to brandish it, but the police officers wrested control of the baton away from Defendant and arrested him. Defendant was charged with one count of carrying a deadly weapon. The circuit court granted Defendant's motion to suppress evidence of the baton. The ICA vacated the circuit court's order, concluding that the seizure was incident to a valid weapons search. The Supreme Court reversed, holding that the police violated Defendant's constitutional rights by approaching him, asking for his identification, and seizing his backpack. View "State v. Weldon" on Justia Law

The Supreme Court vacated Defendant's conviction for operating a vehicle under the influence of an intoxicant, holding that the district court erroneously advised Defendant with regard to his right to testify in the context of a consolidated suppression hearing and trial.After he was charged, Defendant filed a motion to suppress statements he allegedly made to the police officer who arrested him. The district court consolidated the hearing on Defendant's motion to suppress with his bench trial and provided Defendant with several advisements about his right to testify. Defendant declined to testify, and the district court granted the motion to suppress in part. The court then found Defendant guilty. The intermediate court of appeals affirmed. The Supreme Court vacated Defendant's conviction and remanded the case for further proceedings, holding that Defendant did not knowingly, intelligently, and voluntarily waive his right to testify for the purposes of the pre-trial suppression hearing. View "State v. Chang" on Justia Law