Justia Civil Rights Opinion Summaries

The State charged Defendant with violating Haw. Rev. Stat. 291E-61(a)(1) and/or (a)(3) for operating a vehicle under the influence of an intoxicant (OVUII), but the complaint did not allege mens rea. During trial, Defendant moved for a judgment of acquittal and to strike all testimony about breath alcohol content. The district court interpreted this statement as a motion for judgment of acquittal as to section 291E-61(a)(3). The district court granted the motion and subsequently found Defendant guilty of violating section 291E-61(a)(1) only. The intermediate court of appeals (ICA) instructed the district court to dismiss without prejudice the portion of the complaint alleging a violation of section 291E-61(a)(1) because the charge was deficient for failing to allege mens rea. At issue on appeal was whether double jeopardy barred Defendant's re-prosecution for violating section 291E-61. The Supreme Court affirmed, holding (1) the collateral estoppel principle prohibited the State from re-litigating breath alcohol content, whether in a re-prosecution of Defendant on the section 291E-61(a)(3) method of proof, or as part of the State's evidence in a subsequent trial on the section 291E-61(a)(1) method of proof; and (2) collateral estoppel would not prohibit the State from re-charging Defendant on the section 291E-61(a)(1) method of proof. View "State v. Spearman" on Justia Law

Petitioner, an inmate, submitted a petition for a writ of mandamus seeking an order directing the Director of the Department of Public Safety (DPS) to approve dental treatment, teeth cleaning, a root canal, a cavity fix, cancer treatment, and treatment for concussion for brain trauma. The Supreme Court declined to grant the requested relief, as (1) Petitioner failed to demonstrate that DPS was purposefully ignoring or failing to respond to his dental or medical needs; and (2) the documents attached to the petition demonstrated that DPS provided Petitioner medical and dental care within the purview of the State's services, apprised Petitioner of the option to seek outside care for services not covered by the State, and offered services for pain relief. View "Tierney v. Sakai " on Justia Law

In 2009, the State charged Petitioner with the offense of accident involving death or serious bodily injury in violation of Haw. Rev. Stat. 291C-12. After a trial, the court found Petitioner guilty as charged. The intermediate court of appeals (ICA) affirmed Petitioner's conviction. Petitioner appealed, contending that the indictment was fatally defective, a challenge that was raised for the first time on appeal. The Supreme Court vacated the judgment of the ICA and dismissed the case without prejudice, holding (1) the indictment against Petitioner failed to allege the requirements of Haw. Rev. Stat. 291C-14(a) and (b); and (2) under the circumstances of this case, Petitioner was prejudiced by this defect in the indictment. View "State v. Ngo" on Justia Law

After a jury trial, Petitioner was convicted by the district court of committing assault in the third degree in the course of a mutual affray. The intermediate court of appeals (ICA) affirmed Petitioner's conviction but vacated his sentence and remanded for resentencing. The Supreme Court vacated Petitioner's conviction, holding (1) Petitioner's argument that he was immune from the district court's jurisdiction because of the legitimacy of the Kingdom government was without merit; but (2) the district court violated Petitioner's right to a jury trial because Petitioner demanded a jury trial, and his departure from the courtroom during his trial did not operate as an implied waiver of this right. In addition, the Court held that there was sufficient evidence to negate Petitioner's claim of self-defense. View "State v. Kaulia" on Justia Law

Respondents initiated an action against Petitioner and others based on an investigation conducted by the Office of Consumer Protection. Petitioner subsequently filed the present action against Respondents, alleging that Respondents were liable for malicious prosecution, negligent investigation, negligent failure to train and/or supervise, and punitive damages arising from the initiation and maintenance of the earlier action. The court found in favor of Respondents. The intermediate court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the trial court's amended final judgment, holding (1) a plaintiff may bring an action in tort for the maintenance of a malicious prosecution as well as for the initiation of a malicious prosecution; (2) the trial court properly granted summary judgment for Respondents on Plaintiff's claims of maintenance of a malicious prosecution and initiation of a malicious prosecution; but (3) the court erred in failing to state its rationale for granting in part Petitioner's motion for review and/or to set aside taxation of costs. Remanded. View "Arquette v. State" on Justia Law

After a second jury trial, Petitioner was found guilty of attempted sexual assault in the first degree, kidnapping-no voluntary release, attempted assault in the third degree, and assault in the third degree. The Supreme Court (1) affirmed Petitioner's convictions for assault in the third degree; (2) vacated Petitioner's convictions for attempted sexual assault in the first degree and kidnapping; and (3) vacated the court's sentence on Petitioner's convictions for assault in the third degree, holding that the circuit court erred by permitting the State to introduce evidence of acts allegedly committed by Petitioner for which a jury had acquitted him in the prior trial because the evidence violated the principle of collateral estoppel embodied in the double jeopardy clause of the Hawai'i Constitution. View "State v. Mundon" on Justia Law

Defendant was charged with excessive speeding in violation of Haw. Rev. Stat. 291C-105(a). After the charge was read, Defendant moved to dismiss the charge, arguing that it failed to state the requisite state of mind under Haw. Rev. Stat. 702-204. The court denied Defendant's motion, ruling that when a statute does not expressly set forth the culpable state of mind, but rather imports the mens rea element from Haw. Rev. Stat. 702-212 that obviated the need of the State to articulate a state of mind. The district court subsequently convicted Defendant of the charge. The Supreme Court vacated the judgment and instructed the district court to dismiss the charge without prejudice, holding (1) the offense of driving at an excessive speed is not a strict liability offense and requires proof that the defendant acted intentionally, knowingly, or recklessly, an thus, the requisite states of mind must be alleged in a charge of this offense; (2) the section 291C-105(a) charge against Defendant failed to allege the requisite states of mind; and (3) the State also failed to lay an adequate foundation to admit a laser instrument reading of Defendant's vehicle's speed into evidence. View "State v. Gonzalez" on Justia Law

While traveling to California to meet his obligations in a pending matter in that state's courts, Petitioner, who was on release in an unrelated criminal proceeding in the circuit court, was arrested at the Honolulu International Airport. Petitioner's arrest led to the drug charge in the instant court proceedings. Petitioner posted bail and was released from custody. Petitioner proceeded to California, where he was held in custody. Petitioner was not present for his arraignment because he was in custody in California. The circuit filed a a bail forfeiture judgment. The circuit court later denied Petitioner's motion to set aside bail forfeiture and for return of bail. The Supreme Court vacated the judgment of the intermediate court of appeals and held the that circuit court erred in denying Petitioner's motion because, under the circumstances, Petitioner's incarceration in California established good cause for his failure to appear at his arraignment, and thus for why the bail forfeiture judgment should not be executed. View "State v. Diaz" on Justia Law

Petitioner was charged with promoting a dangerous drug in the third degree. Prior to trial, Petitioner filed a motion to suppress seeking to preclude the State from introducing methamphetamine obtained during a warrantless search of Petitioner's pockets. The circuit court suppressed the evidence. The intermediate court of appeals (ICA) vacated the suppression order and remanded to the court for entry of its findings and conclusions regarding whether the State met its burden of establishing by clear and convincing evidence that the methamphetamine would have been inevitably discovered by lawful means pursuant to State v. Lopez. On remand, the court again ordered the evidence suppressed. The ICA ordered the second suppression order vacated and the case remanded for trial, concluding that the circuit court did not make factual findings regarding the events relevant to the issue of inevitable discovery. The Supreme Court vacated the judgment of the ICA and affirmed the circuit court's judgment, holding that the circuit court was not wrong in holding that the State failed to present clear and convincing evidence that the methamphetamine would have inevitably been discovered. View "State v. Rodrigues" on Justia Law

Defendant Steve Cabagbag allegedly stole a truck from a storage facility as well as several tools from a construction site. A jury found Defendant guilty of unauthorized control of a propelled vehicle and theft in the second degree. The trial court sentenced Defendant to two concurrent five-year terms of probation. The intermediate court of appeals (ICA) affirmed. Defendant appealed, arguing that the circuit court committed plain error for failing to provide a jury instruction regarding eyewitness identification because the jury's attention was not adequately drawn to the identification issue. The Supreme Court affirmed, holding (1) in criminal cases, the circuit courts must give the jury a specific eyewitness identification instruction whenever identification evidence is a central issue in the case, and it is requested by the defendant; (2) a circuit court may, in the exercise of its discretion, give the instruction if it believes the instruction is otherwise warranted in a particular case; (3) this new rule should be given prospective effect; and (4) Defendant's conviction is affirmed under the rule then in effect when he was tried.