Justia Civil Rights Opinion Summaries

Articles Posted in Supreme Court of Hawaii
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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

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The Supreme Court reversed Defendant's conviction of assault against a law enforcement officer in the second degree, holding that the record did not reflect an on-the-record exchange sufficient to constitute the true colloquy required to establish a knowing and intelligent waiver of Defendant's constitutional right to a jury trial. Defendant was convicted after a bench trial. On appeal, Defendant argued that the district court reversibly erred in failing to obtain a valid on-the-record waiver of his constitutional right to a jury trial. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgments of the ICA and the district court, holding that, under the totality of the circumstances, the record did not reflect an on-the-record exchange sufficient to constitute the true colloquy required to establish a knowing and intelligent waiver of Defendant's constitutional right to a jury trial. View "State v. Ernes" 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 judgment of conviction and sentence, holding that Defendant's fundamental due process right to present a complete defense was violated when the circuit court prohibited Defendant from presenting state of mind evidence relevant to his self-defense claim. Defendant was convicted of the attempted murder in the second degree of David Quindt, Jr. The attempted murder charge arose from an altercation between Defendant and Quindt, and the primary disputed issue at trial was whether Defendant acted in self-defense. The ICA affirmed the convictions. Before the Supreme Court, Defendant argued that the circuit court erred by prohibiting him from presenting evidence relevant to his self-defense claim, in violation of his constitutional right to present a complete defense. The Supreme Court agreed and reversed, holding that the circuit court erred in altering and excluding Defendant's state of mind evidence, and the error was not harmless beyond a reasonable doubt. View "State v. Williams" on Justia Law

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The Supreme Court reversed Defendant's conviction of promoting a dangerous drug in the third degree, holding that Defendant's due process right to a fair trial was implicated by the lack of a correction of a police officer's false testimony before conclusion of trial, and the error was not harmless. Defendant appealed the circuit court's denial of his motion for a new trial, asserting that he met the intermediate court of appeals' (ICA) four-part test for a new trial based on false testimony from a material prosecution witness and that his right to a fair trial was violated because Officer Douglas Korenic testified falsely during trial. The ICA affirmed. The Supreme Court reversed, holding (1) Defendant satisfied the ICA's four-part test for a new trial based on false testimony from a material prosecution witness under State v. Teves, 679 P.2d 136 (1984); and (2) Defendant's right to a fair trial was violated because Officer Korenic gave false testimony, and there was a reasonable possibility the false testimony contributed to Defendant's conviction. View "State v. Stone" on Justia Law

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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

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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

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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