Justia Civil Rights Opinion Summaries

Defendant was convicted of unauthorized entry into motor vehicle in the first degree. Before trial, the State filed a motion to determine the voluntariness of a statement Defendant made to the police. The circuit court granted in part and denied in part the State’s motion, finding that Defendant’s statement to a police officer that “I wouldn’t have to punch people if they didn’t upset me” was a voluntary statement and was admissible. The statement was made during the police officer’s “effort to make small talk and calm [Defendant] down.” The intermediate court of appeals affirmed, concluding that the absence of prior Miranda warnings by the police officer did not provide a basis to suppress Defendant’s “spontaneous and volunteered statement.” The Supreme Court reversed, holding (1) Defendant’s right against self-incrimination was violated because the police officer subjected Defendant, a person in custody pursuant to an arrest, to “interrogation” without the protection of a Miranda advisement; and (2) the circuit court abused its discretion in admitting evidence of 2006 prior bad acts. Remanded for a new trial. View "State v. Kazanas" on Justia Law

Civil Beat requested the disciplinary records of twelve Honolulu Police Department (HPD) officers who were suspended for various types of misconduct. HPD denied the request in its entirety. Civil Beat then filed a complaint seeking an order directing HPD to disclose the information Civil Beat sought. The circuit court ruled in favor of Civil Beat, concluding that police officers have a “non-existent” privacy interest in their disciplinary suspension records. The Supreme Court vacated the circuit court’s judgment, holding that police officers have a significant privacy interest in their disciplinary suspension records, and disclosure of the records is appropriate when the public interest in access to the records outweighs this privacy interest. Remanded for a determination of whether the public interest outweighs the officers’ significant privacy interests. View "Peer News LLC v. City & County of Honolulu" on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. The district court denied Defendant’s motion to suppress the breath test results and found Defendant guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Guard " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII), Defendant was taken to the police station, where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant moved to suppress the breath test results, arguing that he did not voluntarily consent to breath testing. The district court denied the motion and convicted Defendant of OVUII. The intermediate court of appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, the district court erred in denying Defendant’s motion to suppress the breath test result. View "State v. Bayudan " on Justia Law

After being arrested for OVUII, Defendant was taken to the police station, where he was read an implied consent form. After being informed of the sanctions for refusal, Defendant elected to take a blood test, which resulted in a blood alcohol reading above the legal limit. Defendant was ultimately convicted of OVUII. The Intermediate Court of Appeals upheld the conviction. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s blood test was the product of a warrantless search, and accordingly, Defendant’s conviction could not be upheld. View "State v. Elberson " on Justia Law

After being arrested for OVUII, Defendant was read an implied consent form. Defendant elected to take a blood test, which resulted in a blood alcohol reading above the legal limit. Defendant filed a motion to suppress the blood test results, arguing that the results were obtained in violation of the Fourth Amendment. The district court denied the motion to suppress, and Defendant was convicted of OVUII. The Supreme Court reversed, holding that, in accordance with State v. Won, the result of Defendant’s blood test was the product of a warrantless search, and accordingly, Defendant’s conviction could not be upheld. View "State v. Reilly " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII) Defendant was taken to the police station, where he was read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant filed a motion to suppress the breath test results. The district court denied the motion to suppress. Thereafter, Defendant was convicted of OVUII. The Intermediate Court of Appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, Defendant’s OVUII conviction could not be upheld. Remanded. View "State v. Shigemura " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII) Defendant was taken to the police station, where he was read an implied consent form. Defendant subsequently elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant filed a motion to suppress the breath test results. The district court denied Defendant’s motion to suppress, and Defendant was convicted of OVUII. The Intermediate Court of Appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, Defendant’s OVUII conviction could not be upheld. View "State v. Kernstock " on Justia Law

After being arrested for operating a vehicle under the influence of an intoxicant (OVUII) Defendant was taken to the police station, where he was read an implied consent form. The consent form conveyed a threat of imprisonment and punishment for refusal to submit to a breath test. Defendant subsequently elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant filed motions to suppress evidence of his breath test, arguing that he did not constitutionally consent to the breath test because his consent was coerced by the implied consent form. The district court denied Defendant’s motions to suppress. Defendant was convicted of OVUII. The Intermediate Court of Appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, Defendant’s OVUII conviction could not stand. View "State v. Mikawa " on Justia Law

Defendant was arrested for operating a vehicle under the influence of an intoxicant (OVUII) and was taken to the police station, where he was read an implied consent form. Defendant chose to take a breath test, which resulted in an elevated breath alcohol content reading. Defendant filed a motion to suppress the breath test result, arguing that his consent was coerced by the implied consent form. The motion to suppress was denied, and Defendant was adjudged guilty of OVUII. The Intermediate Court of Appeals (ICA) vacated the district court’s judgment. The Supreme Court affirmed, holding that the result of Defendant’s breath test was the product of a warrantless search. Remanded. View "State v. Richardson " on Justia Law