Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Hawaii
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In this taxation dispute between the County of Maui and Appellees, which leased land on the island of Maui to operate their wind farms, the Supreme Court upheld the Tax Appeals Court's (TAC) final judgment in favor of Appellees, holding that the TAC properly held that the County exceeded its constitutional authority by amending Maui County Code 3.48.005 to expand its definition of "real property" to include "personal property." The County included the value of Appellees' wind turbine in their real property tax assessments and redefined the term "real property" within section 3.48.005 of the MCC to include wind turbines for that purpose. The TAC concluded that the County exceeded its authority under Haw. Const. art. VIII, 3 because the delegates to the 1978 Constitutional Convention did not intend to grant counties the power to redefine "real property." The Supreme Court affirmed, holding that the County exceeded its constitutional power when it amended MCC 6.48.005 to redefine "real property." View "In re Tax Appeal of Kaheawa Wind Power, LLC v. County of Maui" on Justia Law

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The Supreme Court vacated Defendant's conviction of attempted murder in the second degree arising from the stabbing of Defendant's friend, holding that the jury's discovery of "stains" during an improper examination of Defendant's clothing to search for evidence of blood during deliberations was not harmless beyond a reasonable doubt. During deliberations, the jurors requested scissors to cut open the packaging containing Defendant's clothing, and three of the jurors examined the clothing for blood. The jurors found small spots on the inside of the pants and determined that the spots must be blood. The stains had not been introduced as evidence during trial. The Supreme Court vacated Defendant's conviction, holding that the jurors' discovery of the stains constituted an outside influence that may have tainted the jury's impartiality, and the jury's exposure to the stains was not harmless beyond a reasonable doubt. View "State v. Pitts" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction and sentence, holding that the deputy prosecuting attorney (DPA) improperly referenced a pathologist's testimony as a defense expert in two of the most well-publicized murder trials in Hawai'i within the last decade, which affected Defendant's substantial right to a fair trial. Defendant was convicted of manslaughter and sentenced to twenty years of incarceration. On appeal, Defendant challenged the DPA's cross-examination of James Navin, N.D., who had testified in the murder trials involving Kirk Lankford and Matthew Higa, and closing arguments about that testimony. The ICA affirmed. The Supreme Court vacated the ICA's judgment on appeal and remanded the case for further proceedings, holding that the DPA committed misconduct in referencing Navin's testimony, and the error deprived Defendant of her right to a fair trial. View "State v. Udo" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) reversing the judgment of the circuit court granting Defendant's motion to suppress evidence gathered from a search of Defendant's residence, holding that the ICA erred in not accepting the circuit court's findings of fact and in concluding that the particularity requirement was satisfied. As the basis for his motion to suppress Defendant argued that the search warrant did not state with specificity the subunit of the multiple-occupancy building he resided in. The circuit court concluded that the search warrant did not describe Defendant's subunit with particularity and that the search violated Defendant's constitutional rights. The ICA reversed, holding that there residence was not a multiple-occupancy building. The Supreme Court reversed, holding (1) the warrant was invalid because it did not particularly describe Defendant's unit; and (2) the search violated Defendant's constitutional rights. View "State v. Rodrigues" on Justia Law

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In this criminal case, the Supreme Court vacated the sentence set forth in the circuit court judgment and affirmed by the intermediate court of appeals (ICA) and otherwise affirmed the lower courts' judgments, holding that the State violated Defendant's due process rights. Defendant was convicted of four offenses. The ICA vacated three of the convictions. On remand, the State was given the option of either retrying Defendant on the charges underlying three convictions vacated by the appellate court or dismissing two of those charges and having the trial court reinstate the conviction on the remaining charge. Defendant filed a motion to dismiss the three counts, arguing that Hawai'i Rules of Penal Procedure (HRPP) Rule 48 (b)(3) had been violated. The circuit court denied the motion. The State failed to disclose which two of the three charges would be dismissed before Defendant exercised the right of allocution at sentencing. Defendant was subsequently resentenced. The ICA affirmed. The Supreme Court vacated the sentence, holding ((1) the ICA correctly concluded that the circuit court did not err by denying Defendant's motion to dismiss for violation of Rule 48(b)(3); but (2) Defendant's right of allocution was violated by the court’s failure to require timely disclosure of the offense for which Defendant would be sentenced. View "State v. Carlton" on Justia Law

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The Supreme Court held in this case that the governor was permitted to make an interim appointment when the term of an official who is statutorily permitted to holdover expires and the senate is not in session. Michael Champley's term as commissioner of the Hawai'i Public Utilities Commission was set to expire on June 30, 2016. The 2016 legislative session ended on May 5, 2016 without the governor submitting a nomination for a new commission to replace Champley. On June 28, 2016, Champley stated that he intended to continue to serve as "holdover" commissioner until his successor was appointed and confirmed by the senate. The next day, however, the governor announced that he intended to exercise his constitutional authority to temporarily fill the vacancy to appoint Thomas Goran to replace Champley following the expiration of Champley's term. Plaintiff filed a complaint and quo warranty petition against Gorak and the State, alleging that no vacancy existed, and therefore, the interim appointment power of the governor was not implicated. The circuit court granted Gorak's motion for summary judgment. The Supreme Court affirmed, holding that a vacancy existed upon the expiration of Champley's term as commissioner, and therefore, the governor was entitled to appoint Goran on an interim basis. View "Morita v. Gorak" on Justia Law

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The Supreme Court vacated Defendant's conviction and remanded the case for further proceedings, holding that the trial court erred in determining that Defendant's confession was voluntarily made despite an interrogating officer informing him, untruthfully, that he did not pass a polygraph test, holding the deliberate falsehood regarding the polygraph results impermissibly tainted Defendant's confession. The trial court admitted Defendant's confession into evidence over defense objection. The court further ruled that during Defendant's trial testimony, when discussing the circumstances of his confession, could not mention the words "polygraph" or "test" or that the interrogating officer gave him inaccurate test results before his confession was elicited. The Supreme Court vacated the conviction, holding (1) the admission of Defendant's confession was not harmless error; (2) the exclusion of evidence of the circumstances surrounding the eliciting of Defendant's confession severely compromised Defendant's constitutional right to a fair trial and to present a complete defense; and (3) the court's jury instruction that defined an element of the charged offense contained a misstatement of law and was ambiguous and incomplete. View "State v. Matsumoto" on Justia Law

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In this case concerning the admissibility of a suggestive eyewitness or show-up identification, the Supreme Court set forth new rules and because the holdings apply only prospectively to events occurring after publication of this decision, the Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction. Defendant was charged with one count of burglary in the first degree. Before trial, Defendant filed a motion to suppress a witness's show-up identification. The State stipulated that the procedure employed by the police department was impermissibly suggestive, but the circuit court nonetheless denied the motion, finding the witness's identification sufficiently reliable. The jury then found Defendant guilty as charged. The ICA affirmed. The Supreme Court affirmed but set forth new rules in this opinion regarding whether an eyewitness identification procured through an impermissibly suggestive procedure is nonetheless sufficiently reliable under the totality of the circumstances to be admitted in evidence. View "State v. Kaneaikala" on Justia Law

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In this suit filed by a mother living on the island of Lana'i and her two school-age daughters, the Supreme Court held that the State was constitutionally required to make all reasonable efforts to provide access to Hawaiian immersion education. Article X, section 4 of the Hawai'i Constitution imposes on the State a duty to provide for a Hawaiian education program in public schools that is reasonably calculated to revive the Hawaiian language. Today, there are Hawaiian immersion schools on five of the major Hawaiian Islands, but no such program exists on the island of Lana'i. Plaintiffs argued that the provision of the Constitution obligating the State to provide for a Hawaiian education program in public schools requires the State to provide her daughters with access to a public Hawaiian immersion education. The Supreme Court agreed and vacated the circuit court's judgment insofar as it granted the State's motion for partial summary judgment, holding that providing reasonable access to Hawaiian immersion education is currently essential to reviving the Hawaiian language, and therefore, it is a necessary component of any program that is reasonably calculated to achieve that goal. View "Clarabal v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction for assault in the second degree, holding that Defendant's constitutional right to confrontation was violated when the circuit court refused to allow cross-examination of the complaining witness on topics relevant to her bias, interest, or motive for testifying against Defendant, and the error was not harmless beyond a reasonable doubt. On appeal, Defendant argued that the trial court erred in refusing to allow him to cross-examine the complaining witness regarding her pending misdemeanor assault charge arising from the same incident for which Defendant was charged, as well as her probation status resulting from a separate assault charge. The Supreme Court agreed, holding that Defendant's constitutional right to confront witnesses was violated, and because the exclusion of the information might have contributed to the jury's decision to convict, the violation of Defendant's right to confrontation was not harmless beyond a reasonable doubt. View "State v. Brown" on Justia Law