Justia Civil Rights Opinion Summaries

Defendant was arrested for operating a vehicle under the influence of an intoxicant (OVUII). Defendant was subsequently taken to the police station where she read an implied consent form, which conveyed a threat of imprisonment and significant punishment for refusal to submit to a breath, blood, or urine test. Defendant chose to take a breath test. Defendant was later convicted of OVUII. Defendant filed a motion to suppress the breath test result, arguing that she did not constitutionally consent to the breath test because her consent was coerced by the implied consent form. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment and remanded to the district court, holding that, in light of State v. Won, the result of Defendant’s breath test is the product of a warrantless search. View "State v. Tavares " on Justia Law

Defendant was convicted of entering or remaining in a public park during posted closure hours in violation of Honolulu ordinances. Defendant waived the “involvement” of a public defender after consulting with the public defender’s office before trial. The Intermediate Court of Appeals affirmed the conviction. The Supreme Court vacated Defendant’s conviction and remanded the case for a new trial, holding that Defendant’s waiver of his right to counsel was not knowingly and intelligently made, as the district court failed to conduct a formal inquiry regarding Defendant’s waiver of his right to counsel. View "State v. Deming " on Justia Law

Defendant was stopped by police officers while driving his vehicle and was subsequently arrested for operating his vehicle under the influence of an intoxicant. Defendant was asked to submit to a test for the purpose of determining alcohol concentration. The police informed Defendant of his right to refuse to consent to a bodily search but told him if he exercised that right, his refusal to consent would result in a potential thirty-day term of imprisonment. The intermediate court of appeals upheld Defendant’s blood alcohol concentration (BAC) test and the statutory scheme imposing sanctions for withdrawing consent. Defendant appealed, arguing that the BAC evidence in this case was obtained in an unconstitutional manner and should have been suppressed. The Supreme Court reversed, holding that the result of Defendant’s breath test, the product of a warrantless search, was not admissible into evidence because voluntary consent was not demonstrated, and no other exception to the warrant requirement was applicable. View "State v. Won" on Justia Law

A jury found Defendant guilty of committing robbery in the second degree. The jury was not required to find that Defendant had any prior convictions. The prosecution filed a post-conviction motion for the mandatory minimum term of imprisonment and introduced into evidence the judgment for Defendant’s prior convictions. The circuit court took judicial notice on file for both of Defendant’s prior convictions and granted the State’s motion for imposition of mandatory minimum period of imprisonment. Defendant appealed, asserting that, in accordance with Alleyne v. United States, a jury should have considered the facts alleged in the prosecution’s motion for imposition of a mandatory minimum sentence. The Intermediate Court of Appeals affirmed. The Supreme Court affirmed, holding (1) repeat offender sentencing under section 706-606.5 enhances the penalty of the crime committed, and therefore, a defendant’s predicate prior conviction(s) must be alleged in the charging instrument; (2) a jury is required to find that the defendant’s prior conviction(s) have been proved beyond a reasonable doubt to trigger the imposition of a mandatory minimum sentence under section 706-606.5; but (3) these rules are given prospective effect only. View "State v. Auld" on Justia Law