Justia Civil Rights Opinion Summaries

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

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

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

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

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 order of the circuit court modifying and affirming the decision of the Zoning Board of Appeals, which affirmed the decision of the Director of the City and County of Honolulu Department of Planning and Permitting approving an application for a Waikiki Special District (WSD) permit for PACREP to develop the second phase of a condo-hotel at 2139 Kuhio Avenue, holding that, under the circumstances, the due process rights of Local 5, a union representing hotel and restaurant employees, were violated.In appealing the permit, Local 5 argued that the Director abused his discretion by approving the permit without certain restrictive covenant conditions. The Supreme Court agreed, holding that, when the Director removed certain conditions from a WSD permit for the first phase of the condo-hotel project, conditions he knew Local 5 had advocated for, Local 5 should have had an opportunity challenge the removal of those conditions from the permit. Because Local 5 did not receive notice that the Director had removed these conditions, Local 5's due process rights were violated. View "Unite Here! Local 5 v. Department of Planning & Permitting/Zoning Board of Appeals" 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