Justia Criminal Law Opinion Summaries

The Supreme Court of the State of Hawai'i affirmed the judgment of the Intermediate Court of Appeals upholding the conviction of Michael Pickell for operating a vehicle under the influence of an intoxicant. The case centered around the legality of a traffic stop initiated by a Maui County police officer who observed Pickell executing a U-turn at a highway intersection with left turn only markings and signage but no signage explicitly prohibiting U-turns. Pickell argued that in the absence of an express sign prohibiting U-turns, as required by Hawai'i Revised Statutes (HRS) § 291C-82(c), the officer lacked reasonable suspicion to make the traffic stop. The court held that the Maui County ordinance, which requires drivers to follow the directional movements exhibited on markings and signage at intersections, was neither preempted by HRS § 291C-82(c) nor in conflict with it. Therefore, the officer had reasonable suspicion to initiate the traffic stop based on a violation of the Maui County ordinance, and the motion to suppress evidence from the stop was properly denied. View "State v. Pickell" on Justia Law

The Supreme Court vacated the circuit court's judgment, conviction, and sentence related to sentencing in this case, holding that the circuit court erred by not articulating a clear and comprehensive rationale for each of Defendant's consecutive sentences.Pursuant to a plea agreement, Defendant pled no contest to three felony counts. The court sentenced Defendant to consecutive five-year terms on each count for a total of fifteen years. The intermediate court of appeals (ICA) affirmed, thus rejecting Defendant's jurisdictional and sentencing challenges. The Supreme Court vacated the ICA's judgment on appeal and the circuit court's judgment related to sentencing and otherwise affirmed, holding (1) if the State files a complaint in district court and that court lawfully commits the case to circuit court then the circuit court has jurisdiction; and (2) the circuit court did not provide adequate independent grounds to impose each consecutive sentence. View "State v. Bautista" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Defendant for promoting prostitution in violation of Haw. Rev. Stat. 712-1203(1), holding that a reasonable juror could not have concluded that Defendant profited from prostitution within the meaning of Haw. Rev. Stat. 712-1201.After a jury trial, Defendant was found guilty of promoting prostitution. Defendant filed a motion for judgment of acquittal or, in the alternative, motion for new trial, which the circuit court denied. The intermediate court of appeals affirmed, rejecting Defendant's argument that she could not have profited from prostitution under the facts of this case. The Supreme Court reversed, holding that the State failed to prove that Defendant "profit[ed] from prostitution" within the meaning of section 712-1201(2). View "State v. Ibarra" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the judgment of the trial court denying Defendant's motion to correct the credit he received against his sentence, holding that, under Haw. Rev. Stat. 706-671(1), presentence detention time must be counted only once against the aggregate of a defendant's consecutive sentences.The Supreme Court also held (1) under section 706-671(2), time served against concurrently-running probation sentences that are later revoked and converted to consecutive terms of imprisonment must be counted only once against the aggregate of a defendant's consecutive sentences in one or more cases; and (2) when detention or prison time is accrued before sentences or pursuant to a later-revoked probationary sentence, the prohibition on multiple punishments is not violated if the defendant's total period of detention and imprisonment does not exceed the statutory maximum term for the offenses at issue. View "State v. Vaden" on Justia Law

In this criminal case, the Supreme Court held that the district court and intermediate court of appeals (ICA) erred in ruling that Defendant was not entitled to the requisite Miranda warnings when she was questioned by law enforcement officers, holding that "if a person is unable to leave a place of interrogation due to circumstances incident to medical treatment, determining whether the person is 'in custody' under a totality of circumstances requires an inquiry into whether the person was at liberty to terminate the interrogation and cause the officer to leave."State v. Ketchum, 34 P.3d 1006 (Haw. 2001), articulated that a person is "in custody" for constitutional purposes if the totality of the circumstances reflects that the point of arrest has arrived because probable cause to arrest has developed. State v. Sagapolutele-Silva, 511 P.3d 782 (Haw. 2002), overruled Ketchum's bright-line rule and said that the existence of probable cause was only a factor in determining whether someone was entitled to Miranda warnings under the totality of the circumstances. Here, the Supreme Court expressly overruled Sagapolutele-Silva's abrogation of the Ketchum rule and held that the Ketchum rule remained in effect. The Court then held that, based on the totality of the circumstances, Defendant was in custody well before probable cause developed, and therefore, the lower courts erred by holding that Miranda warnings were not required. View "State v. Hewitt" on Justia Law

The Supreme Court affirmed Defendants' convictions for attempted murder in the second degree, kidnapping, and other crimes but remanded the case for a new extended term sentencing hearing and resentencing, holding that that extended term sentencing instructions and special interrogatories were prejudicially erroneous and misleading.The jury selection process in the underlying proceedings identified prospective jurors by a number, not name. On appeal, Defendants argued that the circuit court's jury selection method violated their constitutional right to a presumption of innocence and an impartial jury. The Supreme Court disagreed and affirmed the convictions, holding that there was no constitutional violation. The Court, however, held that Defendants' life without the possibility of parole sentences for attempted murder could stand because the circuit court's extended term sentencing jury instructions and special interrogatories were prejudicially erroneous and misleading. View "State v. Lafoga" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the judgment of the circuit court granting the State's motion for revocation of probation and resentencing Defendant to five years of imprisonment with credit for time served, holding that there was no error.After probation officers conducted a warrantless search of Defendant's home and recovered a firearm and ammunition, the circuit court revoked Defendant's probation. At issue on appeal was whether the circuit court abused its discretion by imposing a probation condition allowing warrantless searches by a probation officer for contraband. The ICA affirmed. The Supreme Court affirmed, holding that because Defendant was prohibited from owning or possessing firearms and ammunition and because he had notice that the term "contraband" would include such items, the circuit court did not abuse its discretion by imposing the special condition. View "State v. Talo" on Justia Law

The Supreme Court reversed the ruling of the family court that the prosecution had proven that DM, a minor who stabbed another minor, had committed attempted assault in the first degree beyond a reasonable doubt, holding that the family court inadequately assessed the circumstances from DM's perspective in rejecting DM's self-defense defense.After a bench trial, during which DM argued that he lacked intent and acted in self-defense, the family court adjudicated DM as having committed attempted assault in the first degree. DM appealed, challenging the court's self-defense-related findings and conclusions. The Supreme Court reversed, holding (1) the family court wrongly rejected DM's defense by inadequately assessing his conduct from his perspective and by misapplying key self-defense elements; and (2) there was not substantial evidence to support the family court's conclusion that the State proved beyond a reasonable doubt that DM's use of deadly force was unjustified. View "In re DM" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that, contrary to Defendant's arguments on appeal, the requirements of Haw. Rev. Stat. 327C-1 does not apply to all criminal cases involving death.Defendant was charged with murder in the second degree. A jury found Defendant guilty of the lesser-included offense of manslaughter based on reckless conduct. The ICA affirmed. The Supreme Court affirmed, holding (1) a death determination under section 327C-1 was not required or implicated under the circumstances of this case because there was sufficient evidence for a reasonable juror to conclude that death was proven beyond a reasonable doubt; and (2) the circuit court did not err in failing to instruct the jury on the lesser-included offense of reckless endangering second. View "State v. Angei" on Justia Law

The Supreme Court vacated the decision of the intermediate court of appeals (ICA) affirming order of the circuit court denying Defendant's motion to dismiss indictment against him, the court's judgment of conviction and sentence, and the later order of restitution, holding that the circuit court abused its discretion by denying Defendant's motion to dismiss the indictment.In his motion to dismiss the indictment against him, Defendant argued that the prosecutor committed prosecutorial misconduct by before the grand jury by improperly eliciting testimony that he had invoked his right to remain silent. The circuit court denied the motion to dismiss, and Defendant entered a no-contest plea to assault in the first degree. The ICA affirmed. The Supreme Court vacated the lower courts' decisions, holding (1) the prosecutor violated Defendant's due process right to a fair and impartial grand jury hearing by eliciting testimony that Defendant invoked his right to remain silent; and (2) the circuit court erred by ordering Defendant to pay $1,461,444 in restitution. View "State v. Borge" on Justia Law