Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Hawaii
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The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) vacating the circuit court's order granting Defendant's motion to suppress evidence obtained in a search of Defendant's bedroom, holding that the circuit court erred in suppressing all evidence obtained by the State.In granting Defendant's motion to suppress, the circuit court determined that Defendant possessed a reasonable expectation of privacy in his bedroom and that the police officer coerced Defendant into opening his bedroom door. The court then suppressed all statements, evidence, observations and actions that were obtained after entry into the bedroom. The ICA vacated the circuit court's order, holding that an emergency aid exception justified the warrantless search. The Supreme Court affirmed on different grounds, holding that, even if the officers unlawfully searched Defendant's bedroom, the evidence obtained did not constitute suppressible "fruit of the poisonous tree." View "State v. Lee" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that the district court rejected evidence which, if admitted, would have presented an essential factual issue for the trier of fact.After Defendant was arrested and charged with assault, one of the medical examiners, Dr. Martin Blinder, who examined Defendant opined that Defendant suffered from amphetamine psychosis and may be entitled to a lack of penal responsibility defense. The State filed a motion for a finding of inadmissibility seeking to preclude Dr. Blinder from testifying at trial. The circuit court prevented Dr. Blinder from testifying on the grounds that State v. Young, 999 P.2d 230 (Haw. 2000), had determined that a drug-induced mental illness was self-induced intoxication prohibited as a defense by Haw. Rev. Stat. 702-230(1). Defendant was convicted of assault second, and the ICA affirmed. The Supreme Court remanded the case for further proceedings, holding (1) the self-induced intoxication exception of section 702-230(1) applies only when a defendant is under the temporary influence of voluntarily ingested substances at the time of an act; and (2) by precluding Dr. Blinder's testimony at trial, the circuit court violated Defendant's due process right to present a complete defense. View "State v. Abion" on Justia Law

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In response to a question certified to it by the United States Court of Appeals for the Ninth Circuit the Supreme Court answered that the statute of limitations for a regulatory takings claim brought under the Hawai'i Constitution is six years pursuant to the catch-all statute of limitations in Haw. Rev. Stat. 657-1(4).The underlying dispute arose from the State Land Use Commission's (LUC) reclassification in 2011 of 1,060 acres of land in South Kohala on Hawai'i Island. In 2017, DW Aina Le'a Development (DW) filed this complaint alleging that the reclassification was an unconstitutional taking because the LUC failed to compensate DW for damages resulting from the land's reclassification. The federal district court dismissed the case, applying the two-year statute of limitations found in Haw. Rev. Stat. 657-7. LW appealed, arguing that the "catch-all" six-year statute of limitations applied to the action. The Ninth Circuit certified to the question to the Supreme Court. The Supreme Court held that the statute of limitations for a takings claim under the Hawai'i Constitution is six years pursuant to Haw. Rev. Code 657-1(4). View "DW Aina Le'a Development, LLC v. State Land Use Commission" on Justia Law

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The Supreme Court reversed the denial of relief and dismissal of Appellant's Hawai'i Rules of Penal Procedure (HRPP) Rule 40 petition, holding that Appellant was entitled to appropriate relief because Appellant's counsel was ineffective.Appellant was convicted of promoting a dangerous drug in the second degree and prohibited acts related to drug paraphernalia. The intermediate court of appeals (ICA) affirmed. After the deadline had passed for filing a writ of certiorari, Appellant filed an application for writ of certiorari challenging the ICA's decision. The Supreme Court dismissed the application because it was untimely. Appellant then filed a pro se petition for post-conviction relief pursuant to Rule 40, alleging that he was denied effective assistance of counsel because appellate counsel failed timely to apply for writ of certiorari despite assuring Appellant that she would do so. The circuit court denied relief. The ICA affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) appellate counsel was ineffective; and (2) appropriate relief in this case was allowing Appellant to refile an application for writ of certiorari in his original case so that the Supreme Court can decide to accept or reject it on the merits. View "Villados v. State" on Justia Law

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The Supreme Court held that, under the totality of the circumstances in this case, the results of Defendant's breath test were admissible because Defendant validly consented to the breath test.After police arrested Defendant for habitually operating a vehicle under the influence of intoxicants an officer read Defendant the Honolulu Police Department's (HPD) implied consent form. Defendant signed and initialed the form consenting to the breath test. Defendant filed a motion to suppress the results of the breath test, arguing that his consent was not knowing, intelligent, and voluntary because the form did not comply with the implied consent statutory scheme and was, therefore, inaccurate. The circuit court suppressed Defendant's breath test results. The intermediate court of appeals (ICA) vacated the circuit court's order, concluding that suppression of Defendant's breath test was not the proper remedy for non-compliance with Haw. Rev. Stat. Chapter 291E procedures. The Supreme Court affirmed, holding (1) the implied consent form here complied with Chapter 291E and was not inaccurate or misleading; and (2) only inaccuracies in implied consent forms that are reasonably likely to influence an arrestee to consent will require suppression. View "State v. Hosaka" on Justia Law

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The Supreme Court affirmed the judgment of the intermediate court of appeals and the circuit court's judgment convicting Defendant of assault in the second degree, holding that the prosecutor's misconduct in this case violated Defendant's due process right to a fair trial.Defendant was convicted of assault in the second degree in connection with an incident involving Defendant's wife (CW). The only witnesses to the incident at the time the injury were Defendant and CW. During trial, the prosecutor made at least eight improper statements during closing argument, and the misconduct affected the central issue to Defendant's self-defense claim of whether he acted with the intent to protect himself. The Supreme Court remanded the case, holding that the strength of the evidence in support of self-defense, the protracted nature of the prosecutorial misconduct, and the court's ineffective curative instructions led to the conclusion that the misconduct was not harmless beyond a reasonable doubt. View "State v. Conroy" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that Defendant's privilege against self-incrimination was infringed when the circuit court permitted the jury to view a video of Defendant invoking that privilege.Defendant was charged with attempted murder in the second degree and assault in the first degree as a result of an altercation with another person during which Defendant allegedly punched and kicked that person multiple times. During trial, the State played for the jury a video of a detective interviewing Defendant that concluded with Defendant declining the detective's request that Defendant reenact the altercation. The jury convicted Defendant of attempted murder in the second degree. The ICA affirmed. The Supreme Court remanded the case for a new trial, holding that Defendant invoked his right to remain silent when he declined to participate in a reenactment of the encounter and that his right to do so was infringed when the prosecution played the police interview video before the jury at trial. View "State v. Beaudet-Close" on Justia Law

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The Supreme Court vacated the opinion of the Intermediate Court of Appeals (ICA) vacating the circuit court's order granting Defendant's motion to suppress all evidence seized as a result of the execution of a search warrant, holding that the amount of time afforded to Defendant to respond to police officers' demand for entry was not reasonable.Police officers broke down Defendant's front door at approximately 6:15 a.m. after they knocked, announced their presence, and demanded entry four times within a twenty-five-second period. The officers had no reason to believe that Defendant was fleeing or that any evidence was being destroyed. Defendant, who was charged with drug offenses, filed a motion to suppress, arguing that the execution of the warrant violated Haw. Rev. Stat. 803-37 and Haw. Const. art. I, 7. The circuit court granted the motion to suppress. The ICA vacated their circuit court's order, concluding that Defendant was afforded a reasonable amount of time to respond to the police's demand for entry to serve the search warrant. The Supreme Court disagreed, holding (1) giving an occupant only twenty-five seconds to respond at such an early morning hour was unreasonable; and (2) there were no exigent circumstances that would have justified breaching the door earlier than would have otherwise been reasonable. View "State v. Naeole" on Justia Law

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The Supreme Court vacated the Intermediate Court of Appeals' (ICA) judgment on appeal and the circuit court's amended judgment convicting Defendant of burglary in the first degree, holding that Defendant was denied the right to effective assistance at trial.On appeal, Defendant argued that her trial counsel provided ineffective assistance by failing to adduce critical evidence impeaching the credibility of the State's key witness. The Supreme Court agreed and vacated Defendant's conviction, holding that, when viewed as a whole, the adequacy of counsel's representation was not within the range of competence demanded of counsel in criminal cases. View "State v. Salavea" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the judgment of the circuit court convicting Defendant of sexual assault in the first degree and sexual assault in the third degree, holding that Defendant's confession should not have been admitted against him at trial.Defendant gave his confession during a custodial interrogation. At issue on appeal was whether Defendant's constitutional right against self-incrimination was violated by the admission of his confession. The ICA affirmed the circuit court's ruling that the confession was voluntarily given. The Supreme Court reversed, holding (1) due to law enforcement's coercive tactics and deception about incontrovertible physical evidence Defendant's confession was involuntary under the totality of the circumstances; and (2) the admission of Defendant's statement was not harmless error. View "State v. Baker" on Justia Law