Justia Criminal Law Opinion Summaries

Defendant was found guilty of operating a vehicle under the influence of an intoxicant and operating a vehicle after license and privilege have been suspended or revoked for operating a vehicle under the influence of an intoxicant. Defendant appealed, arguing, among other things, that the district court erred in permitting the State to amend the charge against to Defendant to allege the required mens rea for the offense. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA correctly concluded that the district court properly permitted the State to amend the charge; and (2) Defendant’s remaining claims lacked merit. View "State v. Kam " on Justia Law

The family court adjudged Defendant guilty of violating an order of protection. Defendant was sentenced to two years’ probation. The start date of Defendant’s trial had been continued numerous times due to court congestion, and when Defendant appeared for a calendar call, Judge Jeannette Castagnetti was ill and could not proceed with trial, which led to another continuance. The day before trial began, Defendant made a motion to dismiss because trial was not commenced within six months of his arrest. The family court denied the motion, concluding that Judge Castagnetti’s one-month absence due to illness met the Haw. R. Pen. P. 48 criteria for excludable periods of time. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal, holding that the family court’s ruling that Judge Castagnetti’s illness constituted “good cause” was in error, and therefore, the ICA erred by concluding that the family court properly denied Defendant’s motion to dismiss pursuant to Rule 48. View "State v. Hayata " on Justia Law

Defendant was arrested for suspicion of operating a vehicle under the influence of an intoxicant (OVUII). Thereafter, Defendant was taken to the police station, where he was read an implied consent form. Defendant decided to take a breath test, which resulted in an elevated breath alcohol content reading. Defendant moved to suppress the breath test results on the basis that he did not knowingly or voluntarily consent to breath or blood testing. The district court denied the motion and convicted Defendant of OVUII. The Intermediate Court of Appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search due to the coercion engendered by the implied consent form. View "State v. Parker " on Justia Law

Defendant was arrested for suspicion of operating a vehicle under the influence of an intoxicant and subsequently taken to the police station, where he was read an implied consent form. Defendant elected to take a breath test, which resulted in an elevated breath alcohol content reading. Defendant moved to suppress the breath test results, arguing that his Fourth Amendment rights were violated. The circuit court denied the motion. The Intermediate Court of Appeals affirmed. The Supreme Court vacated the lower court’s judgments, holding that the result of Defendant’s breath test was the product of a warrantless search due to the coercion engendered by the implied consent form. Remanded to the circuit court for further proceedings. View "State v. Moniz " on Justia Law

Defendant was arrested for operating a vehicle under the influence of an intoxicant (OVUII) and taken to the police station. After reading an implied consent form, Defendant elected to take a breath test. Defendant filed a motion to suppress the breath test result. 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. Remanded. View "State v. Shimkus " on Justia Law

Defendant was found guilty of operating a vehicle after license and privilege have been suspended or revoked for operating a vehicle under the influence of an intoxicant. The intermediate court of appeals (ICA) vacated the district court’s judgment and remanded the case for a new trial based on the district court’s misstatement of the standard of proof. On certiorari, Defendant argued that the ICA erred in concluding that the district court properly allowed the State to amend the charge against Defendant to allege the required mens era for the offense. The Supreme Court affirmed, holding (1) the ICA correctly determined that the district court properly permitted the State to amend the charge; and (2) Defendant’s remaining claims lacked merit. View "State v. Abordo " on Justia Law

Petitioner was found guilty of operating a vehicle under the influence of an intoxicant. Petitioner appealed, arguing that the district court erred in admitting his blood alcohol test results into evidence in violation of his Fourth and Fifth Amendment rights because the implied consent form that apprised him of the criminal refusal penalties was contrary to his constitutional right to withdraw his consent to a warrantless search. The Supreme Court vacated the district court’s judgment, holding that the result of Defendant’s blood test was the product of a warrantless search, and therefore, the district court erred in denying Petitioner’s motion to suppress the blood test result. View "State v. Terasako " on Justia Law

Petitioner was found guilty of operating a vehicle under the influence of an intoxicant. Petitioner appealed the denial of his motion to suppress the results of a breath alcohol test that he took after he was arrested, arguing that he did not constitutionally consent to the breath test because the implied consent form conveyed a threat of imprisonment and significant punishment for his refusal to submit to the test. The Supreme Court vacated the judgment, holding that the result of Petitioner’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Petitioner’s motion to suppress the breath test result. Remanded. View "State v. Cheek-Enriques " on Justia Law

Petitioner entered a conditional plea to the charges of habitually operating a vehicle under the influence of an intoxicant and of driving while license suspended or revoked. Petitioner subsequently appealed the denial of his motion to suppress evidence of a breath alcohol test that he took after he was arrested. Specifically, Petitioner contended that he did not constitutionally consent to the breath test because his consent was coerced by the implied consent form, which conveyed a threat of imprisonment and significant punishment for his refusal to submit to the test. The intermediate court of appeals affirmed the denial of Petitioner’s motion to suppress. The Supreme Court vacated the lower courts’ judgments, holding that the result of Petitioner’s breath test was the product of a warrantless search because the implied consent form was coercive. Remanded with instructions to enter an order granting Petitioner’s motion to suppress and to allow Petitioner to withdraw his conditional guilty plea as to both charges. View "State v. Lee " 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 she was read an implied consent form. Defendant chose to take a breath test, which resulted in an elevated breath alcohol content. The district court adjudged 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 Defendant’s consent was coerced by the implied consent form, which conveyed a threat of imprisonment and significant punishment for refusal to submit to a breath test. Consequently, the result of Defendant’s breath test was the product of a warrantless search, and the district court erred by denying Defendant’s motion to suppress the breath test result. View "State v. Murphy " on Justia Law