Justia Constitutional Law Opinion Summaries

Articles Posted in Hawaii Supreme Court

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Petitioner pleaded no contest to one count of assault in the first degree and one count of kidnapping as a class B felony. In its first minimum term order, the Hawaii Paroling Authority (HPA) set Petitioner's minimum term of imprisonment at eighteen months for each count. After Petitioner had been imprisoned for more than six months, the HPA held a second hearing to allow Complainant to testify. At the conclusion of the hearing, the HPA imposed a minimum term of five years imprisonment on each count. Petitioner subsequently filed a petition for post-conviction relief, arguing that the HPA violated his constitutional rights to due process and equal protection by reopening his minimum term hearing and by subsequently increasing his minimum term. The circuit court dismissed Petitioner's petition. Petitioner appealed, arguing, inter alia, that the HPA wrongfully withheld evidence from him prior to the second hearing. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA judgment and circuit court order, holding that the ICA erred in concluding that Petitioner waived his due process claim relating to the HPA's nondisclosure of adverse materials in Petitioner's HPA file. Remanded for an evidentiary hearing. View "De La Garza v. State " on Justia Law

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Plaintiff brought this suit against the City and County of Honolulu and the State, challenging the approval of a rail project and arguing that state law required that an archaeological inventory survey be completed prior to any approval or commencement of the project. The circuit court granted summary judgment in favor of the City and State on all of Plaintiff's claims. The Supreme Court vacated the circuit court's judgment on Plaintiff's claims that challenged the rail project under Haw. Rev. Stat. 6E and remanded. Plaintiff subsequently requested that the Supreme Court award $255,158 in attorney's fees and $2,510 in costs against the City and State for work performed in the trial court. The Supreme Court (1) granted Plaintiff's request for appellate attorney's fees and costs against the City in the amount of $41,192 in attorney's fees and $343 in costs; (2) and denied Plaintiff's request for trial level fees and costs without prejudice, as Plaintiff's request for fees and costs attributable to work performed at the trial level was more properly within the trial court's discretion. View "Kaleikini v. Yoshioka" on Justia Law

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Defendant was found guilty of several drug-related offenses. At his sentencing hearing, Defendant was represented by a court-appointed deputy public defender. Privately retained counsel also appeared on behalf of Defendant and sought to substitute for the deputy public defender. Defendant's privately retained counsel requested a continuance to prepare. The circuit court denied Defendant's motion to substitution of counsel and a continuance as untimely. The court then sentenced Defendant to a term of imprisonment. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's and circuit court's judgment, holding that the circuit court violated Defendant's constitutional right to counsel of his choice when it denied his motion for substitution of counsel and a continuance of the sentencing hearing, as the court did not properly balance Defendant's right to counsel of his choice against countervailing government interests. Remanded. View "State v. Cramer" on Justia Law

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After a jury trial, Defendant was convicted of manslaughter and carrying or use of a firearm in the commission of a felony. The intermediate court of appeals affirmed. The Supreme Court affirmed, holding (1) the circuit court did no abuse its discretion in denying Defendant's motion to dismiss the amended complaint; (2) the circuit court did not plainly err in allowing the testimony of two witnesses without formally qualifying them as expert witnesses and substituting the words "opinion testimony" for the word "expert" in the jury instruction; (3) the circuit court did not plainly err in instructing the jury on self-defense, in failing to sua sponte instruct the jury on defense of property, or in failing to provide a cautionary instruction on the use of medical marijuana; and (4) Defendant failed to establish that his trial counsel was ineffective. View "State v. Metcalfe" on Justia Law

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The State charged Defendant with violating Haw. Rev. Stat. 291E-61(a)(1) and/or (a)(3) for operating a vehicle under the influence of an intoxicant (OVUII), but the complaint did not allege mens rea. During trial, Defendant moved for a judgment of acquittal and to strike all testimony about breath alcohol content. The district court interpreted this statement as a motion for judgment of acquittal as to section 291E-61(a)(3). The district court granted the motion and subsequently found Defendant guilty of violating section 291E-61(a)(1) only. The intermediate court of appeals (ICA) instructed the district court to dismiss without prejudice the portion of the complaint alleging a violation of section 291E-61(a)(1) because the charge was deficient for failing to allege mens rea. At issue on appeal was whether double jeopardy barred Defendant's re-prosecution for violating section 291E-61. The Supreme Court affirmed, holding (1) the collateral estoppel principle prohibited the State from re-litigating breath alcohol content, whether in a re-prosecution of Defendant on the section 291E-61(a)(3) method of proof, or as part of the State's evidence in a subsequent trial on the section 291E-61(a)(1) method of proof; and (2) collateral estoppel would not prohibit the State from re-charging Defendant on the section 291E-61(a)(1) method of proof. View "State v. Spearman" on Justia Law

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Petitioner, an inmate, submitted a petition for a writ of mandamus seeking an order directing the Director of the Department of Public Safety (DPS) to approve dental treatment, teeth cleaning, a root canal, a cavity fix, cancer treatment, and treatment for concussion for brain trauma. The Supreme Court declined to grant the requested relief, as (1) Petitioner failed to demonstrate that DPS was purposefully ignoring or failing to respond to his dental or medical needs; and (2) the documents attached to the petition demonstrated that DPS provided Petitioner medical and dental care within the purview of the State's services, apprised Petitioner of the option to seek outside care for services not covered by the State, and offered services for pain relief. View "Tierney v. Sakai " on Justia Law

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In 2009, the State charged Petitioner with the offense of accident involving death or serious bodily injury in violation of Haw. Rev. Stat. 291C-12. After a trial, the court found Petitioner guilty as charged. The intermediate court of appeals (ICA) affirmed Petitioner's conviction. Petitioner appealed, contending that the indictment was fatally defective, a challenge that was raised for the first time on appeal. The Supreme Court vacated the judgment of the ICA and dismissed the case without prejudice, holding (1) the indictment against Petitioner failed to allege the requirements of Haw. Rev. Stat. 291C-14(a) and (b); and (2) under the circumstances of this case, Petitioner was prejudiced by this defect in the indictment. View "State v. Ngo" on Justia Law

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After a jury trial, Petitioner was convicted by the district court of committing assault in the third degree in the course of a mutual affray. The intermediate court of appeals (ICA) affirmed Petitioner's conviction but vacated his sentence and remanded for resentencing. The Supreme Court vacated Petitioner's conviction, holding (1) Petitioner's argument that he was immune from the district court's jurisdiction because of the legitimacy of the Kingdom government was without merit; but (2) the district court violated Petitioner's right to a jury trial because Petitioner demanded a jury trial, and his departure from the courtroom during his trial did not operate as an implied waiver of this right. In addition, the Court held that there was sufficient evidence to negate Petitioner's claim of self-defense. View "State v. Kaulia" on Justia Law

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Respondents initiated an action against Petitioner and others based on an investigation conducted by the Office of Consumer Protection. Petitioner subsequently filed the present action against Respondents, alleging that Respondents were liable for malicious prosecution, negligent investigation, negligent failure to train and/or supervise, and punitive damages arising from the initiation and maintenance of the earlier action. The court found in favor of Respondents. The intermediate court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the trial court's amended final judgment, holding (1) a plaintiff may bring an action in tort for the maintenance of a malicious prosecution as well as for the initiation of a malicious prosecution; (2) the trial court properly granted summary judgment for Respondents on Plaintiff's claims of maintenance of a malicious prosecution and initiation of a malicious prosecution; but (3) the court erred in failing to state its rationale for granting in part Petitioner's motion for review and/or to set aside taxation of costs. Remanded. View "Arquette v. State" on Justia Law

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After a second jury trial, Petitioner was found guilty of attempted sexual assault in the first degree, kidnapping-no voluntary release, attempted assault in the third degree, and assault in the third degree. The Supreme Court (1) affirmed Petitioner's convictions for assault in the third degree; (2) vacated Petitioner's convictions for attempted sexual assault in the first degree and kidnapping; and (3) vacated the court's sentence on Petitioner's convictions for assault in the third degree, holding that the circuit court erred by permitting the State to introduce evidence of acts allegedly committed by Petitioner for which a jury had acquitted him in the prior trial because the evidence violated the principle of collateral estoppel embodied in the double jeopardy clause of the Hawai'i Constitution. View "State v. Mundon" on Justia Law