Justia Criminal Law Opinion Summaries

The Supreme Court vacated the order of the district court suppressing Defendant's statements, vacated the judgment of the intermediate court of appeals (ICA) affirming that Defendant was in custody during the traffic stop, and remanded this case for further proceedings, holding that Defendant was not entitled to suppression of her statements.Defendant was arrested after a traffic stop and charged with operating a vehicle under the influence of an intoxicant and excessive speeding. Defendant filed a motion to suppress statements she made during the traffic stop on the basis that she was not advised of her rights under Miranda v. Arizona, 384 U.S. 436 (1966), during the incident. The district court agreed and granted the motion. The ICA affirmed. The Supreme Court reversed, holding (1) under the totality of the circumstances, Defendant was not in custody when she was pulled over during the administration of the standardized field sobriety test; and (2) because Miranda warnings were not required, there was no illegality that would taint Defendant's subsequent statements as fruit of the poisonous tree. View "State v. Sagapolutele-Silva" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court granting Defendant's motion to dismiss the felony information against him based upon a defective charge, holding that the ICA correctly determined that the State should have provided the statutory definition of "substantial bodily injury" in the charging document at issue.The State charged Defendant by felony information with the offense of assault in the second degree, in violation of Haw. Rev. Stat. 707-711(1)(a) and/or (d). Defendant filed a motion to dismiss, arguing that the felony information did not provide notice as to the definitions of "substantial bodily injury" or "dangerous instrument," and therefore the charge was defective. The circuit court granted the motion and dismissed the case. The ICA affirmed. The Supreme Court affirmed, holding (1) the State must include the statutory definition of "substantial bodily injury" in a charge of second-degree assault under section 707-711(a); and (2) the State waived its argument that discovery materials provided Defendant with actual knowledge of the charges against him. View "State v. Jardine" on Justia Law

The Supreme Court affirmed the decision of the intermediate court of appeals (ICA) affirming the judgment of the circuit court denying Defendant's motion to suppress evidence, holding that the police officers' actions did not constitute a breaking and that the search of a gray backpack did not exceed the terms of the search warrant in this case.On appeal, Defendant argued that the evidence against him should be excluded because police officers failed to comply with the requirements set forth in Haw. Rev. Stat. 803-37 that officers "demand entrance" before entering a building and because the search of his backpack exceeded the terms of the search warrant executed by the officers. The Supreme Court affirmed, holding (1) the purposes of Haw. Rev. Stat. 803-37 were satisfied when the officers' entry did not create any risk of harm; and (2) the searches of Defendant's backpack did not exceed the terms of the search warrant. View "State v. Keanaaina" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) to the extent it affirmed the denial of Defendant's motion for a deferred acceptance of no contest (DANC) plea, holding that the circuit court's consideration of sexual penetration was an abuse of discretion under the circumstances.Defendant was indicted for the sexual assault of a twelve-year-old and accepted a plea agreement allowing her to plead no contest to an amended charged of sexual assault in the fourth degree. Defendant moved for DANC plea, which the circuit court denied. The ICA affirmed the denial of Defendant's DANC motion. The Supreme Court vacated the judgment below, holding that Defendant's no contest plea to sexual assault in the fourth degree excluded any allegation of sexual penetration. View "State v. Satoafaiga" on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction for disorderly conduct, holding that the trial court lacked sufficient evidence to convict Defendant of disorderly conduct.Defendant was arrested by lying in front of trucks scheduled to transport telescope components for the Daniel K. Inouye Solar Telescope along with other protestors and then convicted of disorderly conduct. The ICA affirmed the conviction, concluding that the State's evidence was sufficient to support the conviction. The Supreme Court reversed, holding that Defendant's disorderly conduct conviction was unsupported by substantial evidence. View "State v. Kaeo" on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) determining that the criminal complaint against Defendant did not comply with Haw. Rev. Stat. 805-1 but that a non-compliant complaint could still be used to initiate and maintain a prosecution by penal summons, holding that the family court erred in issuing a penal summons.The State charged Defendant by complaint with abuse of a household or family member, but the complaint was neither signed by a complainant nor supported by a declaration. The family court issued a penal summons compelling Defendant to appear. After appearing, Defendant filed a motion to dismiss, arguing that the complaint was deficient, and therefore, the family court lacked probable cause to issue the penal summons. The family court granted the motion to dismiss. The ICA vacated the family court, concluding that the district court did not err in issuing the penal summons. The Supreme Court reversed, holding (1) section 805-1 does not distinguish between complaints for penal summons and complaints for arrest warrants; and (2) therefore, the ICA erred in holding that the State need not comply with its statutory obligations simply because it sought a penal summons. View "State v. Thompson" on Justia Law

The Supreme Court held that the gravity of a crime, by itself, does not establish an exigency empowering law enforcement officers to bypass the warrant requirement and that the State must articulate objective facts showing an immediate law enforcement need for the entry to support a warrantless home intrusion under the exigency exception.The State invoked the exigent circumstances exception to justify a warrantless home entry into Defendant's residence. Defendant was subsequently indicted for attempted murder in the second degree. Defendant moved to suppress the evidence found during the search of his residence, arguing that the police lacked exigent circumstances to enter his residence without a warrant. The trial court granted the motion to suppress. The Supreme Court affirmed, holding that the police entered Defendant's home without exigent circumstances, permission, or a warrant, and therefore, the circuit court properly suppressed the evidence. View "State v. Willis" on Justia Law

The Supreme Court held that courts cannot impose imprisonment exceeding the statutory threshold for a probationary sentence and also conditions of probation, and therefore, Defendant's sentence in this case was unlawful.Defendant pled no contest to violating a temporary restraining order. The family court sentenced Defendant to 181 days in prison and ordered him to complete a domestic violence intervention program (DVI). On appeal, Defendant argued that the family court erred in sentencing him to both serve 181 days and complete DVI because imposing DVI without probation violates Haw. Rev. Stat. Stat. 706-624(2)(a). The Supreme Court agreed and vacated the family court's sentence, holding that because a misdemeanor defendant sentenced to imprisonment exceeding 180 days cannot also receive a probationary sentence, and because DVI cannot be imposed except as a condition of probation, the family court imposed an unlawful sentence in this case. View "State v. Agdinaoay" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's Haw. R. Pen. P. 35(b) motion to reduce his sentence for negligent homicide in the first degree and two drug-related charges, holding that the trial court did not abuse its discretion in denying Appellant's Rule 35(b) motion.The circuit court imposed two concurrent five-year terms of imprisonment to run consecutively with a ten-year term of imprisonment. In his Rule 35(b) motion, Appellant requested that his five-year sentences run concurrently, rather than consecutively, with his ten-year sentence. The circuit court denied the motion, and the intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding that courts deciding Rule 35(b) motions are not required to consider the Haw. Rev. Stat. 706-606 sentencing factors. View "State v. Cattaneo" on Justia Law

The Supreme Court vacated the judgment of the intermediate appellate court (ICA) and the circuit court's order denying Appellant's eighth Haw. R. Pen. P. Rule 40 petition for post-conviction relief, holding that Appellant raised colorable claims in his petition.Appellant was convicted of murder and sentenced to life imprisonment. In his eighth Rule 40 petition, Appellant argued that the trial court erred by ordering restitution without first determining whether Appellant could afford it and that it was error that he be denied parole for nonpayment of restitution. The circuit court denied the petition without holding a hearing. The ICA affirmed. The Supreme Court vacated the orders below, holding (1) Appellant stated a colorable claim that the Hawai'i Paroling Authority denied parole due to nonpayment of restitution; and (2) State v. Johnson, 711 P.2d 1295 (Haw. 1985), did not create a "new rule," and the ICA erred in concluding that the Johnson rule did not retroactively apply to Defendant's sentence. View "Rapozo v. State" on Justia Law