Justia Criminal Law Opinion Summaries

Defendant was found guilty of operating a vehicle without motor vehicle insurance in violation of Haw. Rev. Stat. 431:10C-104 and sentenced to a $500 fine. Defendant filed a notice of appeal and requested waiver of her transcript costs pursuant to Haw. Rev. Stat. 802-7. The Intermediate Court of Appeals (ICA) denied Defendant’s request for waiver, concluding that Defendant was not a “criminal defendant” as required by the statute. Defendant proceeded with her appeal, arguing that the district court erred by failing to adjudicate her case pursuant to Haw. Rev. Stat. Chapter 291D. The ICA affirmed, holding that Chapter 291D does not apply to violations of section 431:10C-104. The Supreme Court vacated the ICA’s judgment on appeal and remanded, holding (1) the ICA correctly determined that Chapter 291D did not apply to Defendant’s section 431:10C offense; but (2) the ICA erred in denying Defendant’s request for transcript costs under section 802-7 on the basis that she was not a criminal defendant. View "State v. Godines" on Justia Law

Defendant was arrested for possession of methamphetamine after a routine traffic stop. Defendant was convicted and sentenced for promotion of a dangerous drug in the third degree. Defendant appealed, arguing that the circuit court erred in denying his motion to suppress drug evidence recovered as a result of a canine narcotics screen that was performed on his vehicle. The Intermediate Court of Appeals (ICA) affirmed Defendant’s conviction and the denial of Defendant’s motion to suppress. The Supreme Court vacated the ICA’s judgment, holding that the ICA erred in affirming the denial of Defendant’s motion to suppress, as the canine screen was a separate unlawful seizure not reasonably related in scope to the original traffic stop. Remanded. View "State v. Alvarez" on Justia Law

Defendant was convicted of unauthorized entry into motor vehicle in the first degree. Before trial, the State filed a motion to determine the voluntariness of a statement Defendant made to the police. The circuit court granted in part and denied in part the State’s motion, finding that Defendant’s statement to a police officer that “I wouldn’t have to punch people if they didn’t upset me” was a voluntary statement and was admissible. The statement was made during the police officer’s “effort to make small talk and calm [Defendant] down.” The intermediate court of appeals affirmed, concluding that the absence of prior Miranda warnings by the police officer did not provide a basis to suppress Defendant’s “spontaneous and volunteered statement.” The Supreme Court reversed, holding (1) Defendant’s right against self-incrimination was violated because the police officer subjected Defendant, a person in custody pursuant to an arrest, to “interrogation” without the protection of a Miranda advisement; and (2) the circuit court abused its discretion in admitting evidence of 2006 prior bad acts. Remanded for a new trial. View "State v. Kazanas" on Justia Law

Defendant, a farmer, was transporting cabbages in the back of his uncovered truck when some of the produce spilled out onto the road. The district court found Defendant guilty of violating Haw. Rev. Stat. 291C-131, which prohibits spilling loads on highways. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court reversed, holding (1) the ICA did not err in holding that Defendant was required to present evidence on every element of the defense before he met his burden of production; but (2) Defendant met his burden of production because “reasonable removal” under section 291C-131(c) requires removal of spilled agricultural produce only when the removal is reasonable, and the prosecution did not produce evidence disproving the elements of Defendant’s defense beyond a reasonable doubt. View "State v. Bowman" on Justia Law

After a jury trial, Defendant was convicted of three counts of sexual assault in the first degree and three counts of sexual assault in the third degree. Defendant appealed, arguing, among other things, that expert testimony regarding child sexual abuse is no longer relevant. The intermediate court of appeals (ICA) affirmed the judgment of conviction and sentence. The Supreme Court affirmed, holding (1) the trial court did not err in admitting the expert testimony regarding the unique characteristics of child sexual abuse victims to assist the jury in comprehending delayed reporting; and (2) although Defendant did not properly preserve for appeal his argument that the expert testimony presented in this case was unfairly prejudicial or misleading, the Court provided guidance in light of the ICA’s analysis of this issue. View "State v. Kony" on Justia Law

Defendant was found guilty of operating a vehicle under the influence of an intoxicant (OVUII), in violation of Haw. Rev. Stat. 291E-61(a)(1) and/or (3). The Intermediate Court of Appeals (ICA) affirmed the judgment on appeal. The Supreme Court affirmed, holding (1) the district court did not err in permitting the State to amend Defendant’s section 291E-61(a)(1) charge to allege mens rea; and (2) insofar as the section 291E-61(a)(1) charge was properly amended and insofar as Defendant did not challenge the sufficiency of the evidence supporting his conviction for violating section 291E-61(a)(1), his OVUII conviction still stands, and there is no need to address Defendant’s argument that the breath test result supporting his section 291E-61(a)(3) conviction was obtained in violation of his constitutional rights. View "State v. Fisher " on Justia Law

Defendant was arrested for operating a vehicle under the influence of an intoxicant (OVUII) and read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant moved to suppress the breath test result, arguing that his Fourth Amendment rights were violated. The district court denied the motion. Defendant was subsequently found guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, Defendant’s OVUII conviction could not be upheld. View "State v. Franco " on Justia Law

The district court found Defendant guilty 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 Appeals affirmed. The Supreme Court affirmed, holding (1) the district court properly permitted the State to amend Defendant’s Haw. Rev. Stat. 291E-61(a)(1) charge to allege mens rea; (2) insofar as the section 291E-61(a)(1) charge was properly amended and Defendant did not challenge the sufficiency of the evidence supporting his conviction for violating section 291E-61(a)(1), his conviction stands; and (3) there is no need to address Defendant’s argument that blood test results were obtained in violation of his his Miranda rights, his statutory right to counsel, and his due process rights, and Defendant’s double jeopardy conviction is irrelevant. View "State v. Tuia " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. The district court denied Defendant’s motion to suppress the breath test results and found Defendant guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Guard " on Justia Law

At a bench trial, Defendant, who was cited for excessive speeding, orally moved to suppress the citing officer’s laser gun reading on the grounds that proper foundation for the gun had not been laid. The district court denied the motion, and Defendant was subsequently found guilty. The Intermediate Appellate Court (ICA) affirmed. The Supreme Court reversed, holding that the ICA erred in concluding that the laser speed reading was admissible because the State failed to lay a proper foundation for the admission of the laser gun reading where the requirement regarding the nature and extent of the citing officer’s training was not met. View "State v. Gardner " on Justia Law