Justia Constitutional Law Opinion Summaries

The Supreme Court remanded this criminal matter to the circuit court for further proceedings, holding that the circuit court erred by denying Defendant's motion to suppress as to certain drug evidence.Defendant was convicted of one count of promoting a dangerous drug in the second degree and one count of unlawful use of drug paraphernalia. The intermediate court of appeals (ICA) affirmed. On certiorari, the Supreme Court noticed plain error affecting Defendant's substantial rights with respect to the circuit court's denial of Defendant's motion to suppress. The Court held (1) a dog sniff conducted by the Kauai Police Department (KPD) was unrelated to the initial stop and seizure of the truck driven by Defendant for evidence of the alleged theft of a purse; (2) KPD did not have independent reasonable suspicion to believe the truck contained drugs; and (3) therefore, the dog sniff violated Defendant's constitutional right against unreasonable searches. View "State v. Ikimaka" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals affirming the judgment of the circuit court convicting Defendant of assault in the second degree, holding that Defendant's constitutional right to cross-examine witnesses was violated when the circuit court prevented defense counsel from cross-examining the complainant about a potential source of bias.On appeal, Defendant argued that the circuit court erred in precluding the defense from cross-examining the complainant about disciplinary action the complainant might have faced as a United States Marine for instigating a fight in violation of its code of conduct provisions. Defendant further argued that the court erred in allowing a police officer to testify as to the contents of a security video that recorded the altercation but that had subsequently been destroyed. The ICA affirmed. The Supreme Court reversed, holding that because the defense was prevented from questioning the complainant about a potential source bias, the jury did not have sufficient information from which to make an informed appraisal of the complainant's motives or bias. The Court also provided guidance concerning the admissibility of other evidence as to the contents of a destroyed video recording under Haw. R. Evid. R. 1004 and 403. View "State v. Miranda" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction for operating a vehicle under the influence of an intoxicant, holding that Defendant's untimely filing of his application for writ of certiorari was due to ineffective assistance of counsel, and therefore, this Court may consider the merits of the issues raised in the application.Defendant sought and received an extension of time to file an application for a writ of certiorari. After the extended due date, Defendant filed his application for writ of certiorari. In his motion to accept the untimely application, Defendant argued that the Court should consider his application on the merits because the failure to file within the deadline resulted from either computer system error or his counsel's mistake. The Supreme Court agreed, holding (1) certiorari review is a critical stage of criminal proceedings in which a defendant has the constitutional right to effective assistance of counsel; (2) because defense counsel failed to ensure the timely filing of the certiorari application, Defendant was deprived of the constitutional right to the effective assistance of counsel, and this Court may consider the merits of the issues raised in the certiorari application; and (3) the ICA did not err in affirming the district court's judgment. View "State v. Uchima" on Justia Law

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

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

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

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

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

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

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