Justia Civil Rights Opinion Summaries

Articles Posted in Supreme Court of Hawaii
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The Supreme Court held that the gravity of a crime, by itself, does not establish an exigency empowering law enforcement officers to bypass the warrant requirement and that the State must articulate objective facts showing an immediate law enforcement need for the entry to support a warrantless home intrusion under the exigency exception.The State invoked the exigent circumstances exception to justify a warrantless home entry into Defendant's residence. Defendant was subsequently indicted for attempted murder in the second degree. Defendant moved to suppress the evidence found during the search of his residence, arguing that the police lacked exigent circumstances to enter his residence without a warrant. The trial court granted the motion to suppress. The Supreme Court affirmed, holding that the police entered Defendant's home without exigent circumstances, permission, or a warrant, and therefore, the circuit court properly suppressed the evidence. View "State v. Willis" on Justia Law

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The Supreme Court vacated Defendant's conviction for assault in the first degree and remanded this case to the circuit court, holding that the trial court erred in conditioning the admission of evidence on expert testimony.Defendant killed his cousin, Santhony Albert, but claimed he had acted in self-defense. Defendant was convicted of assault in the first degree, and intermediate court of appeals affirmed. On appeal, Defendant argued that the trial court erred in preventing him from advancing evidence of Albert's blood alcohol concentration (BAC) level unless he called an expert to explain its meaning. The Supreme Court agreed, holding that the trial court erred in conditioning the BAC evidence on expert testimony and violated Defendant's constitutional right to present any and all competent evidence to support his defense. View "State v. David" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the circuit court's order denying Defendant's motion for a new trial, holding that the cumulative impact of misconduct on the part of the prosecutor deprived Defendant of a fair trial and was not harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) at trial, the prosecutor introduced to the jury incriminatory statements allegedly made by Defendant without previously disclosing them to the defense during discovery in violation of Haw. R. Pen. P. 16(b)(1); (2) the prosecutor introduced statements that were incriminating to Defendant that were allegedly made by the complaining witness despite the court's motion in limine ruling barring their introduction; (3) the prosecutor engaged in improper and unnecessarily lurid questioning of defense witnesses to inflame the jury's passions; and (4) the circuit court erred in denying Defendant's motion for a new trial based on prosecutorial misconduct, and the ICA erred in concluding that the prosecutor's misconduct was harmless. View "State v. Williams" on Justia Law

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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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The Supreme Court affirmed the ICA's judgment on appeal except that part of the judgment relating to an additional revocation period for having three or more prior alcohol enforcement contacts, holding that the procedures used by the Administrative Driver's License Revocation Office (the ADLRO) denied Defendant due process.The ADLRO sustained the automatic revocation of Defendant's driver's license for ten years, determining that Defendant was subject to a mandatory ten-year revocation period for operating a vehicle under the influence of an intoxicant because he had three or more prior alcohol enforcement contacts. The ICA affirmed. The Supreme Court vacated the ICA's decision in part, holding that the ADLRO erred in considering two prior alcohol enforcement contacts in determining the length of Defendant's revocation period because Defendant was unable to challenge those convictions at the revocation hearing. View "Wolcott v. Administrative Director of the Courts" 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