Justia Constitutional Law Opinion Summaries

State Department of Education (DOE) issued a request for proposals to provide health and human services under contracts pursuant to Haw. Rev. Stat. 103F. After the DOE rejected the proposal of Petitioner Alaka'i Na Keiki, Inc., Petitioner brought an action against the DOE. The circuit court granted summary judgment in favor of the DOE. The intermediate court of appeals affirmed, concluding that chapter 103F does not allow for judicial review. The Supreme Court vacated the judgment of the lower courts, holding that the DOE's decisions to reject such proposals were subject to judicial review. The Court then held (1) as construed, chapter 103F was not unconstitutional for violating the separation of powers doctrine; (2) Petitioner's request for a declaratory judgment was moot to the extent the subject contracts had been awarded and their terms expired; (3) Petitioner's claim for negligence by the DOE was barred under the State Tort Liability Act; and (4) Petitioner's claim for injunctive relief, premised on the DOE's alleged faulty administration of the contract process, was moot inasmuch as the Court interpreted such process in chapter 103F as subject to judicial review. Remanded.

Petitioner Less Schnabel allegedly caused the death of decedent by one punch. After a jury trial, Petitioner was found guilty of manslaughter and sentenced to twenty years of imprisonment. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment of the ICA, holding (1) the ICA gravely erred in affirming the ruling of the circuit court that the State would be allowed to introduce evidence from the prior juvenile proceedings of Petitioner if Petitioner testified on cross-examination in the instant case that he did not know a single punch could cause the death of a person; and (2) the statement of the deputy prosecuting attorney to the jury during closing arguments not to "get too caught up in the mumbo jumbo of all the words [of the jury instructions,]" among other statements, infringed on Petitioner's right to have the case against him proven beyond a reasonable doubt. Remanded.

Defendant Lloyd Pratt received three citations when he was found residing in a closed area of a state park. Pratt filed a motion to dismiss the charges, asserting as a defense that his activities were constitutionally-protected native Hawaiian practices, and citing State v. Hanapi, which defined the scope in the criminal context of the legal privilege for native Hawaiians to engage in customary or traditional native Hawaiian practices when such practices conflict with State statute or regulations. The district court denied the motion, held trial, and found Pratt guilty on all three charges. The intermediate court of appeals (ICA) affirmed. The Supreme Court granted certiorari to clarify the law surrounding the assertion of native Hawaiian rights as a defense in criminal cases. The Court affirmed, holding (1) the courts below did not err in utilizing a balancing test in this case; (2) in balancing interests, the court must consider the totality of the circumstances; and (3) under the totality of the circumstances test, Pratt's convictions must be affirmed.

In this case the Supreme Court was presented with the question of whether the political question doctrine barred Hawaiian Homes Commission Act (HHCA) beneficiaries from using the Hawaiian Constitution's "sufficient sums" provision to demand more legislative funding of the Department of Hawaiian Home Lands (DHHL) when that provision provided no guidance as to how quickly homesteads must be developed. The Supreme Court held (1) judicial determination of "sufficient sums" as to the purpose of DHHL's administrative and operating expenses is not barred as a nonjusticiable political question, and the intermediate court of appeals (ICA) did not err in so holding; but (2) the political question bars judicial determination of what would constitute "sufficient sums" for the purposes of (a) development of home, agriculture, farm and ranch lots, (b) home, agriculture, aquaculture, farm and ranch loans, and (c) rehabilitation projects, and the ICA erred in concluding otherwise.

Petitioner Michael Tierney was charged with promoting a detrimental drug in the third degree. The trial court determined that Petitioner's fitness to proceed to trial was at issue and ordered a one person panel to examine Petitioner. Petitioner refused to cooperate with the examination. The trial court proceeded to trial without the examiner's opinion and found Petitioner guilty of the charge. The intermediate court of appeals (ICA) affirmed. The Supreme Court reversed, holding (1) when a court orders an examination to determine whether a defendant is fit to proceed to trial pursuant to Haw. Rev. Stat. 704-404(1) and the defendant refuses to cooperate with the examiner, the examiner must produce a report of the examination that expressly states whether such unwillingness of defendant was the result of physical or mental disease, if possible; (2) if it is not possible for the examiner to make that determination, the examiner must expressly state as much; and (3) because the examiner in this case did not state in his report whether Petitioner was fit to proceed or state that it was impossible to make that determination, the district court abused its opinion in proceeding to trial without the examiner's opinion.

Petitioner Kevin Yamahata was adjudged guilty by the district court 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 appeal (ICA) affirmed. Yamahata appealed, contending that the ICA gravely erred in holding that mens rea need not be alleged in either a section 291E-61(a)(1) or (a)(3) charge pursuant to State v. Nesmith. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Yamahata's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Yamahata did not challenge the sufficiency of the evidence as to that basis, his conviction still stood.

Petitioner Emilio Soria was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1). The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's judgment, holding that pursuant to State v. Nesmith, which states that mens rea must be alleged in a section 291E-61(a)(1) charge in order to provide fair notice of the nature and cause of the accusation, the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge. Therefore, Shinsato's section 291E-61(a)(1) charge was deficient for failing to allege mens rea. Remanded to the district court with instructions to dismiss the complaint without prejudice.

Petitioner Rew Shinsato was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Shinsato's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Shinsato did not challenge the sufficiency of the evidence as to that basis, Shinsato's conviction still stood.

Petitioner Alejandro Padilla was adjudged guilty by the district court of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Padilla's section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Padilla did not challenge the sufficiency of the evidence as to that basis, Padilla's conviction still stood.

Petitioner William Daniels was adjudged guilty of operating a vehicle under the influence of an intoxicant, in violation of Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA gravely erred in holding that mens rea need not be alleged in a section 291E-61(a)(1) charge, and therefore, Daniels' section 291E-61(a)(1) charge was deficient for failing to allege mens rea; but (2) insofar as the section 291E-61(a)(3) charge was sufficient, and insofar as Daniels did not challenge the sufficiency of the evidence as to that basis, Daniels' conviction still stood.