Justia Criminal Law Opinion Summaries

The Supreme Court reversed in part the decision of the intermediate court of appeals (ICA) affirming the decision of the district court granting Defendant's motion to suppress his answers to the medical rule-out questions given subsequent to a traffic stop, holding that the ICA erred in affirming the district court's suppression of Defendant's answers to the medical rule-out questions.In granting Defendant's motion to suppress, the district court found that Defendant was subject to custodial interrogation without being given the required warnings under Miranda v. Arizona, 384 U.S. 436 (1966). The ICA affirmed. The Supreme Court reversed, holding that, under this Court's decision in State v. Sagapolutele-Silva, 511 P.3d 782 (Haw. 2022), Defendant was not in custody when he was asked the medical rule-out questions because the circumstances of the stop had not risen to those of a formal arrest. View "State v. Tronson " on Justia Law

The Supreme Court vacated in part the judgment of the intermediate court of appeals (ICA) affirming the district court's order granting Defendant's motion to suppress statements after finding that Defendant was subject to custodial interrogation without being given Miranda warnings, holding that the ICA erred in affirming the district court's suppression of Defendant's responses to medical rule-out questions.Defendant was arrested and charged with operating a vehicle under the influence of an intoxicant and reckless driving. Defendant moved to suppress his answers to the medical rule-out questions, asserting that he was subject to custodial interrogation without being given Miranda warnings. The ICA affirmed. The Supreme Court vacated the judgment in part, holding (1) because the circumstances of Defendant's stop did not rise to that of a formal arrest Defendant was not in custody at the time he was asked the medical rule-out questions; and (2) therefore, Miranda warnings were not required. View "State v. Vasconcellos " on Justia Law

The Supreme Court vacated Defendant's conviction for continuous sexual assault of a minor under the age of fourteen years, in violation of Haw. Rev. Stat. 707-733.6, holding that two of the deputy prosecuting attorney's closing argument remarks prejudiced Defendant's right to a fair trial.On appeal, Defendant argued that the deputy prosecuting attorney's remarks that (1) Defendant had a "motive to lie"; and (2) the complaining witness testified "consistent with a child who is traumatized" constituted plain error. The Supreme Court agreed and vacated his conviction, holding (1) both of the challenged remarks constituted prosecutorial misconduct; and (2) there was a reasonable possibility that each instance of misconduct, standing alone, contributed to the trial's outcome. View "State v. Hirata" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) in this criminal case, holding that because the information omitted the crime of forgery in the second degree's states of mind, it failed to state an offense as to counts 4-7 and violated Defendant's right to due process.Defendant was charged via information with four counts of forgery in the second decree. Defendant filed a pretrial motion to dismiss counts 4-7 charging him with forgery in the second degree because the information omitted forgery's states of mind. In response, the State argued that intent to defraud is an element, understandable to the common person, and gave notice to Defendant of forgery's state of mind. The circuit court granted Defendant's motion to dismiss. The ICA reversed. The Supreme Court reversed, holding (1) Defendant's information did not identify forgery's states of mind, intentionally and knowingly; and (2) therefore, counts 4-7 failed to state an offense and violated Defendant's right to due process. View "State v. Garcia" on Justia Law

The Supreme Court vacated in part the judgment of the intermediate court of appeals and the order of the circuit court denying Appellant's pro se Haw. R. Penal P. 40 petition challenging the sentencing court's judgment of conviction and sentence, holding that some of the grounds of Appellant's petition raised civil claims required to be transferred for disposition under the civil rules.Appellant pleaded guilty to multiple drug, theft, and firearm-related offenses, and the circuit court imposed concurrent prison terms and various monetary assessments. In his HRPP Rule 40 petition Appellant raised eight grounds challenging his conviction and sentence. The circuit court denied the petition without a hearing, and the intermediate court of appeals affirmed. The Supreme Court reversed, holding (1) the circuit court properly dismissed grounds one through five of Appellant's petition based on waiver; but (2) Appellant raised a colorable claim as to the monetary assessments; and (3) grounds six through eight raised civil claims required to be transferred for disposition under civil rules pursuant to HRPP Rule 40(c)(3). View "Warner v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Defendant's motion to dismiss the charges against him of, among other things, second-degree murder, holding that the State's prosecution of Defendant was unlawful under Haw. Rev. Stat. 801-1.On appeal from his convictions, Defendant argued that the State violated Haw. Rev. Stat. 801-1 by using the complaint and preliminary hearing process to prosecute him for second-degree murder, attempted murder in the first and second degree, and use of a firearm in the commission of a separate felony, holding (1) under section 801-1, criminal defendants cannot be "subject to be tried and sentenced to be punished in any court" for an alleged offense without an indictment or information, unless the charged offense is contempt or within the jurisdiction of the district court; and (2) defendants are "subject to be tried and sentenced to be punished" at arraignment. View "State v. Obrero" on Justia Law

The Supreme Court affirmed in part the judgment of the intermediate court of appeals (ICA) affirming the judgment of the circuit court convicting and sentencing Defendant but reversed with regard to the issue of Defendant's ability to pay a crime victim compensation (CVC) fee under Haw. Rev. Stat. 706-605(6) and 351-62.6, holding that Defendant's inability to pay the CVC fee mandated waiver of the fee.Defendant was convicted of various drug, theft, fraud, and property crimes. In addition to a five-year term of incarceration, the circuit court ordered Defendant to pay a CVC fee and a drug demand reduction (DDR) assessment under Haw. Rev. Stat. 706-650. Defendant appealed, arguing that both the CVC fee and the DDR assessment constituted unconstitutional taxes. The ICA affirmed. The Supreme Court vacated the ICA's judgment as to its imposition of the CVC and affirmed in all other respects, holding (1) the circuit court erroneously imposed the CVC fee upon Defendant because he was unable to pay the fee; and (2) the CVC fee and DDR assessment were not unconstitutional taxes. View "State v. Yamashita" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming Defendant's kidnapping conviction, holding that the circuit court erred in failing to instruct the jury in accordance with State v. Sheffield, 456 P.3d 122 (Haw. 2020), and the error was not harmless beyond a reasonable doubt.After a jury trial, Defendant was convicted of kidnapping as a class A felony and sentenced to twenty years' imprisonment. The ICA affirmed. At issue on appeal was whether the circuit court plainly erred in failing to give the jury a Sheffield instruction in this case. The Supreme Court answered the question in the affirmative, holding that the circuit court erred in failing to so instruct the jury, and the error was not harmless beyond a reasonable doubt. View "State v. Ishimine" on Justia Law

The Supreme Court held that when an officer administers a standardized field sobriety test (SFST) to a person suspected of operating a vehicle under the influence of an intoxicant, the officer is conducting an interrogation under the Hawai'i Constitution by asking "medical rule-out questions."Medical rule-out questions rule out other reasons besides intoxication for poor performance on the SFST. Defendant was asked seven medical rule-out questions while she was in police custody and before she was advised of her rights under Miranda v. Arizona, 384 U.S. 436 (1966). After Defendant was charged with OVUII she filed a motion to suppress, arguing that she was subjected to interrogation when the officer asked if she would like to participate in the SFST. The district court granted the motion. The ICA ruled that the district court erred by suppressing Defendant's response to whether she would participate in the SFST but that that the medical rule-out questions constituted interrogation. The Supreme Court affirmed, holding that the ICA did not err in concluding that Defendant's answers to the medical rule-out questions must be suppressed and that the other challenged evidence was admissible. View "State v. Skapinok" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) vacating in part the district court's conclusion that Defendant's performance on the standardized field sobriety test (SFST) was inadmissible fruit of the poisonous tree, holding that Defendant's performance on the SFST was admissible despite the absence of Miranda warnings preceding the test.Defendant was subject to custodial interrogation during a roadside investigation for operating a vehicle under the influence of an intoxicant. At issue was whether the evidence gathered after that illegality, including his performance on the SFST was testimonial of fruit of the poisonous tree. The Supreme Court affirmed the admission of Defendant's performance on the SFST, holding that the police did not exploit the illegal interrogation because the interrogation did not lead to the discovery of the SFST evidence. View "State v. Manion" on Justia Law