Justia Constitutional Law Opinion Summaries

Randall Hoffman was observed by Officer Warren Tavares of the Hawai‘i State Department of Land and Natural Resources dumping green waste from a trailer on a Kaua‘i roadside. After a verbal exchange and a physical altercation, Hoffman was arrested and charged with assault against a law enforcement officer, resisting arrest, and criminal littering. During the encounter, Hoffman made several statements to Officer Tavares without being Mirandized.The Circuit Court of the Fifth Circuit suppressed all of Hoffman's statements, concluding they were made during custodial interrogation without Miranda warnings. The court found that Officer Tavares's statements were likely to elicit incriminating responses from Hoffman. The State appealed, arguing that the statements were made in response to actions and words normally attendant to arrest and custody.The Intermediate Court of Appeals (ICA) affirmed in part and vacated in part the circuit court's order. The ICA agreed that some of Officer Tavares's statements were likely to elicit incriminating responses and upheld the suppression of Hoffman's statement about being turned away from a county refuse station. However, the ICA ruled that other statements by Hoffman, including his expletive responses and his statement during the scuffle, were voluntary utterances not in response to interrogation.The Supreme Court of the State of Hawai‘i reviewed the case and held that under Article I, Section 10 of the Hawai‘i Constitution, the ultimate inquiry is whether a law enforcement officer knew or should have known that their words or conduct were reasonably likely to elicit an incriminating response. The court affirmed the ICA's decision in part, vacated it in part, and remanded the case for further proceedings, holding that some of Hoffman's statements were indeed responses to interrogation and should be suppressed, while others were not. View "State v. Hoffman" on Justia Law

This case involves a challenge to a statute and a constitutional provision in Hawaii that relate to the prosecution of continuous sexual assault of a minor under the age of fourteen. The defendant, Alvin Tran, was charged with violating this statute. After a trial, a jury found him guilty. Tran then filed a motion for a new trial, arguing that the statute and the constitutional provision violated the U.S. Constitution because they did not require the jury to unanimously agree on the specific acts that constituted the continuous sexual assault. The trial court denied this motion. Tran also filed a motion to dismiss the indictment against him, arguing that it was not specific enough. The trial court granted this motion in part and denied it in part, dismissing the case but allowing the state to refile the charges.The Supreme Court of the State of Hawaii held that the statute and the constitutional provision did not violate the U.S. Constitution. The court reasoned that these provisions did not authorize non-unanimous jury verdicts, which would be unconstitutional. Instead, they allowed a unanimous jury to find a defendant guilty even if the jurors did not agree on which specific acts constituted the continuous sexual assault. The court also held that the indictment against Tran was sufficient. Therefore, the court vacated the trial court's order dismissing the case and remanded the case for further proceedings. View "State v. Tran" on Justia Law

This case involves two appeals by West Maui Resort Partners LP and Ocean Resort Villas Vacation Owners Association against the County of Maui. The appellants, who manage nearly 700 time share units, challenged their Maui County tax assessments, arguing that the County's tax assessments were unconstitutional and violated the County's own code. They contended that the County's creation of a Time Share real property tax classification acted as an illegal tax on time share visitors. They also argued that time share units and hotel units have an identical "use" for real property purposes, and therefore, should be taxed in the same real property tax classification.The Tax Appeal Court granted summary judgment for the County in both cases. The court concluded that the County acted within its constitutional authority to tax real property in creating the Time Share classification and taxing properties assigned to it. The court also found that the County had several legitimate policy purposes rationally related to the creation of the Time Share classification, including raising revenue for infrastructure maintenance and addressing time share properties' unique impacts on the community.The appellants appealed to the Intermediate Court of Appeals, which transferred the cases to the Supreme Court of the State of Hawai‘i. The Supreme Court affirmed the Tax Appeal Court's summary judgment for the County in both cases, concluding that the County did not exceed its constitutional authority when creating the Time Share classification, nor did it violate its own code in doing so. The court also held that the Time Share classification's creation and rates were constitutional under the equal protection clauses of the Hawai‘i and U.S. Constitutions. View "In Re: West Maui Resort Partners LP v. County of Maui" on Justia Law

In the Supreme Court of the State of Hawaii, four plaintiffs, Sonia Davis, Jessica Lau, Lauralee Riedell, and Adam Walton, challenged the actions of the County of Maui, the County of Maui Office of the Mayor, and other related defendants. The dispute arose from a sweep of a large encampment of houseless individuals in Maui County in September 2021. The plaintiffs had requested a contested case hearing before the sweep, which was ignored, and the sweep proceeded as planned, leading to the seizure of Davis and Lau's personal property.The plaintiffs asserted they were denied procedural due process under the state and federal constitutions when the county seized their personal property without proper notice or an opportunity to be heard. The County moved to dismiss, arguing the plaintiffs did not have a protected property interest in continuing to store their belongings on County land. The circuit court granted the motion as to Riedell and Walton, who had not lost property during the sweep, but denied the motion as to Davis and Lau, who had.The Supreme Court affirmed the circuit court's decision. The court held that plaintiffs possessed a property interest in their personal items protected by the Constitution of the State of Hawaii. Therefore, the due process clause required a hearing before the County could seize the plaintiffs’ property. The circuit court properly granted the County’s motion to dismiss Riedell and Walton’s claims because they did not lose property during the sweep and properly denied the County’s motion to dismiss as to Davis and Lau, who did. View "Davis v. Bissen" on Justia Law

Christopher Wilson was charged with offenses related to carrying a firearm and ammunition in public without the appropriate license in Hawaii. In response, Wilson challenged the constitutionality of the relevant Hawaii Revised Statutes (HRS) § 134-25 (2011) (pistol or revolver) and § 134-27 (2011) (ammunition), arguing that these laws violated his rights under the Second Amendment of the U.S. Constitution and its equivalent in the Hawaii constitution, article I, section 17. The Circuit Court of the Second Circuit dismissed the charges, agreeing with Wilson's argument. The State appealed the dismissal.The Supreme Court of the State of Hawaii concluded that Wilson was only entitled to challenge the constitutionality of the laws he was charged with violating. As such, Wilson could challenge HRS § 134-25 and § 134-27, but not HRS § 134-9, which pertains to licenses to carry firearms and which Wilson had not attempted to comply with.The court found that the text, purpose, and historical tradition of the Hawaii Constitution do not support an individual right to carry firearms in public. The court reasoned that the language of article I, section 17, which mirrors the Second Amendment, ties the right to bear arms to the context of a well-regulated militia. It does not extend this right to non-militia purposes. The court also considered Hawaii's history of strict weapons regulation and the intent of Hawaii's framers.Based on these considerations, the court held that HRS § 134-25 and § 134-27 do not violate Wilson's right to keep and bear arms under article I, section 17 of the Hawaii Constitution and the Second Amendment to the U.S. Constitution. The court vacated the lower court's dismissal order and remanded the case back to the Circuit Court of the Second Circuit. View "State v. Wilson" on Justia Law

In a case before the Supreme Court of the State of Hawai'i, the court ruled on the suppression of text message evidence in a sexual assault prosecution. The defendant, Dylan River James, allegedly admitted to the sexual assault during a text conversation with the alleged victim, who was directed by the police to contact him. The lower court suppressed these text messages, agreeing with James' argument that his rights to self-incrimination and counsel were violated. The lower court reasoned that the alleged victim was acting as a government agent, and thus, James should have been given Miranda warnings.The Supreme Court of the State of Hawai'i vacated the lower courts' decisions. The court ruled that James was not in custody at the time of the text exchange, and thus, Miranda warnings were not required under either the federal or state constitutions. The court also ruled that James' right to counsel had not yet been attached, as adversarial judicial criminal proceedings had not yet been initiated.The court further held that the Intermediate Court of Appeals (ICA) made an error in concluding that it did not have appellate jurisdiction over the lower court's order denying the State's motion for reconsideration. The Supreme Court stated that the State's right to appeal from an order granting a defendant’s motion to suppress includes a right to appeal from a related order denying the State’s motion for reconsideration. The case has been remanded to the lower court for further proceedings. View "State v. James" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing this action brought by Academic Labor United (ALU) requesting declaratory judgments that graduate assistants were foreclosed from exercising the collective bargaining rights provided to public employees under Haw. Const. art. XIII, 2 and Haw. Rev. Stat. 89, holding that there was no error.ALU, which represented graduate student employees of the University of Hawaii who wish to engage in collective bargaining, brought this suit arguing that a pair of 1972 decisions of the Hawaii Public Employment Relations Board determined that graduate assistants were not "employees" under chapter 89 and were thus foreclosed from exercising collective bargaining rights. The circuit court dismissed the case on jurisdictional grounds. The Supreme Court affirmed, holding that because ALU had not invoked Hawaii Administrative Rules 12-42-9 to clarify whether its members are employees under chapter 89 and had not exhausted its administrative remedies, the circuit court did not have jurisdiction over ALU's action. View "Academic Labor United v. Bd. of Regents of the University of Haw." on Justia Law

The Supreme Court held that the Office of the Auditor lacked the authority to pierce the attorney-client privilege and obtain an audit's confidential communications and rejected the Office of the Auditor's jurisdiction and non-justiciability bars to the Office of Hawaiian Affairs' (OHA) suit in this declaratory action.The OHA sued the Office of the Auditor after it was audited, seeking a declaratory judgment that neither Haw. Rev. Stat. 23-5 nor the Hawai'i State Constitution required OHA to disclose to the State Auditor privileged attorney-client communications protected from disclosure. The circuit court granted summary judgment for OHA. The Supreme Court affirmed, holding that section 23-5 did not require OHA to disclose to the State Auditor privileged attorney-client communications protected from disclosure pursuant to Haw. R. Evid. 503 and common-law principles. View "Office of Hawaiian Affairs v. Kondo" on Justia Law

In this case challenging the constitutionality of administrative rules governing access to Mauna Kea's summit under Haw. Const. art XII, 7, the Supreme Court answered questions reserved by the Circuit Court of the Third Circuit by holding (1) in a challenge to the constitutionality of administrative rules based on a violation of Haw. Const. art. XII, 7, the burden of proof does not shift to the government agency defendant and instead remains with the challenging party; and (2) the framework set forth in Ka Pa'akai O Ka'Aina v. Land Use Comm'n, 7 P.3d 1068 (Haw. 2000), applies to challenges to the constitutionality of an administrative rule based on an alleged violation of article XII, section 7, in addition to contested case hearings. View "Flores-Case 'Ohana v. University of Haw." on Justia Law

In this criminal case, the Supreme Court held that the district court and intermediate court of appeals (ICA) erred in ruling that Defendant was not entitled to the requisite Miranda warnings when she was questioned by law enforcement officers, holding that "if a person is unable to leave a place of interrogation due to circumstances incident to medical treatment, determining whether the person is 'in custody' under a totality of circumstances requires an inquiry into whether the person was at liberty to terminate the interrogation and cause the officer to leave."State v. Ketchum, 34 P.3d 1006 (Haw. 2001), articulated that a person is "in custody" for constitutional purposes if the totality of the circumstances reflects that the point of arrest has arrived because probable cause to arrest has developed. State v. Sagapolutele-Silva, 511 P.3d 782 (Haw. 2002), overruled Ketchum's bright-line rule and said that the existence of probable cause was only a factor in determining whether someone was entitled to Miranda warnings under the totality of the circumstances. Here, the Supreme Court expressly overruled Sagapolutele-Silva's abrogation of the Ketchum rule and held that the Ketchum rule remained in effect. The Court then held that, based on the totality of the circumstances, Defendant was in custody well before probable cause developed, and therefore, the lower courts erred by holding that Miranda warnings were not required. View "State v. Hewitt" on Justia Law