Justia Constitutional Law Opinion Summaries

Defendant was charged by complaint with one count of unauthorized possession of confidential personal information (UPCPI). Defendant moved to dismiss the complaint. The circuit court granted the motion in part. The intermediate court of appeals vacated the order and remanded for further proceedings. On remand, Defendant moved to dismiss the complaint on the grounds that the UPCPI statutes are unconstitutionally vague and overbroad. In a separate dismissal motion, Defendant alleged that the complaint failed to provide him fair notice of the nature and cause of the accusation. The circuit court dismissed the case, concluding (1) the complaint was fatally defective because it denied Defendant of his right to be fully informed of the nature and cause of the accusation against him, and (2) the UPCPI statutes were not void for vagueness but were overbroad. The Supreme Court affirmed in part and vacated in part, holding (1) the complaint was legally insufficient; (2) the UPCPI statutes are not facially overbroad; and (3) portions of the UPCPI statutes are unconstitutionally vague, but they are severable from the constitutional parts of the statutes. View "State v. Pacquing" on Justia Law

After a jury trial, Defendant was convicted for the attempted murder of his wife. Defendant appealed, arguing that the circuit court violated his rights under the Fourth Amendment of the United States Constitution and Haw. Const. art. I, 7 by denying his motion to suppress. The Intermediate Court of Appeals vacated Defendant’s conviction, concluding that the circuit court erred in applying the plain view doctrine to the discovery of certain evidence. The Supreme Court reversed the ICA’s judgment on appeal and affirmed the trial court’s amended judgment of conviction, holding (1) the ICA adopted an interpretation of the plain view doctrine that is contrary to the Court’s prior decisions and the protections and limits of the rights guaranteed under Haw. Const. art. I, 7; and (2) the warrantless seizure of the evidence at issue was lawful. View "State v. Phillips" on Justia Law

Defendant was arrested for possession of methamphetamine after a routine traffic stop. Defendant was convicted and sentenced for promotion of a dangerous drug in the third degree. Defendant appealed, arguing that the circuit court erred in denying his motion to suppress drug evidence recovered as a result of a canine narcotics screen that was performed on his vehicle. The Intermediate Court of Appeals (ICA) affirmed Defendant’s conviction and the denial of Defendant’s motion to suppress. The Supreme Court vacated the ICA’s judgment, holding that the ICA erred in affirming the denial of Defendant’s motion to suppress, as the canine screen was a separate unlawful seizure not reasonably related in scope to the original traffic stop. Remanded. View "State v. Alvarez" on Justia Law

Defendant was convicted of unauthorized entry into motor vehicle in the first degree. Before trial, the State filed a motion to determine the voluntariness of a statement Defendant made to the police. The circuit court granted in part and denied in part the State’s motion, finding that Defendant’s statement to a police officer that “I wouldn’t have to punch people if they didn’t upset me” was a voluntary statement and was admissible. The statement was made during the police officer’s “effort to make small talk and calm [Defendant] down.” The intermediate court of appeals affirmed, concluding that the absence of prior Miranda warnings by the police officer did not provide a basis to suppress Defendant’s “spontaneous and volunteered statement.” The Supreme Court reversed, holding (1) Defendant’s right against self-incrimination was violated because the police officer subjected Defendant, a person in custody pursuant to an arrest, to “interrogation” without the protection of a Miranda advisement; and (2) the circuit court abused its discretion in admitting evidence of 2006 prior bad acts. Remanded for a new trial. View "State v. Kazanas" on Justia Law

The City and County of of Honolulu provided refuse collection services through the use of front-end loader work crews to service 181 multi-unit residential properties and numerous City agencies. After the City decided to discontinue front loader collection services, United Public Workers (the Union) sued the City and County. The Union filed a motion for a preliminary injunction seeking to enjoin the City from unilaterally implementing the privatization of the collection and disposal services. The circuit court granted partial summary judgment to the Union and permanently enjoined the City from discontinuing the services at issue, concluding that the City and County’s cancellation of the services constituted impermissible privatization. The circuit court certified the partial summary judgment order for appeal and stayed the proceedings as to the remaining counts. The Supreme Court affirmed, holding (1) the City and County’s decision to terminate front loader refuse collection services violated constitutional merit principles and civil service laws and deprived the civil service workers in this case of the protections guaranteed in Article XVI, Section 1 of the Hawaii Constitution and Haw. Rev. Stat. 76 and 77; and (2) the circuit court did not err in granting partial summary judgment in favor of the Union as to the asserted violations of constitutional merit principles. View "Salera v. Caldwell" on Justia Law

Defendant was found guilty of operating a vehicle under the influence of an intoxicant (OVUII), in violation of Haw. Rev. Stat. 291E-61(a)(1) and/or (3). The Intermediate Court of Appeals (ICA) affirmed the judgment on appeal. The Supreme Court affirmed, holding (1) the district court did not err in permitting the State to amend Defendant’s section 291E-61(a)(1) charge to allege mens rea; and (2) insofar as the section 291E-61(a)(1) charge was properly amended and insofar as Defendant did not challenge the sufficiency of the evidence supporting his conviction for violating section 291E-61(a)(1), his OVUII conviction still stands, and there is no need to address Defendant’s argument that the breath test result supporting his section 291E-61(a)(3) conviction was obtained in violation of his constitutional rights. View "State v. Fisher " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. The district court denied Defendant’s motion to suppress the breath test results and found Defendant guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Guard " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station, where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant moved to suppress the breath test results, arguing that he did not voluntarily consent to breath testing. The district court denied the motion and convicted Defendant of OVUII. The intermediate court of appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Bayudan " on Justia Law

After being arrested for OVUII, Defendant was taken to the police station, where he was read an implied consent form. After being informed of the sanctions for refusal, Defendant elected to take a blood test, which resulted in a blood alcohol reading above the legal limit. Defendant was ultimately convicted of OVUII. The Intermediate Court of Appeals upheld the conviction. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s blood test was the product of a warrantless search, and accordingly, Defendant’s conviction could not be upheld. View "State v. Elberson " on Justia Law

After being arrested for OVUII, Defendant was read an implied consent form. Defendant elected to take a blood test, which resulted in a blood alcohol reading above the legal limit. Defendant filed a motion to suppress the blood test results, arguing that the results were obtained in violation of the Fourth Amendment. The district court denied the motion to suppress, and Defendant was convicted of OVUII. The Supreme Court reversed, holding that, in accordance with State v. Won, the result of Defendant’s blood test was the product of a warrantless search, and accordingly, Defendant’s conviction could not be upheld. View "State v. Reilly " on Justia Law