The case concerned defendant Wayne Laeda's convictions on three counts of promoting a dangerous drug in the first degree and three counts of prohibited acts related to drug paraphernalia, arising from controlled purchases of methamphetamine arranged with police assistance. Laeda appealed the denial of his motion for a new trial, contending that a juror’s statements of inability to participate due to memory and hearing issues invalidated the unanimous verdict under constitutional protections. The Hawaii Supreme Court affirmed the judgment, holding that Hawaii Rules of Evidence Rule 606(b) prohibits courts from considering juror affidavits or testimony about internal mental processes or competence during deliberations to impeach the verdict. The court reasoned that such inquiries are limited to external influences and do not extend to a juror’s claimed inability to keep up or deliberate effectively.
The case involved James Kalili appealing his convictions in the Circuit Court of the Third Circuit for five counts of illegal camping in consolidated criminal cases. The Intermediate Court of Appeals of Hawaii affirmed the circuit court's judgments. The court held that Kalili failed to establish that his conduct was constitutionally protected as a native Hawaiian right under the standard set in State v. Hanapi.
The case involved defendant Elijah Eugene Amondson appealing his conviction in Hawaii district court for reckless driving under HRS § 291-2, based on testimony that he was speeding as measured by a laser gun on July 22, 2004. Amondson challenged the admission of the speed reading, the foundation for the officer's qualifications to operate the device, and the sufficiency of evidence to prove reckless disregard for safety. The Intermediate Court of Appeals affirmed the conviction, holding that precedent established the laser gun's admissibility and that the State had laid an adequate foundation for the officer's testimony and testing procedures. The court further concluded there was sufficient evidence under the reckless driving statute and related definitions of recklessness to support the guilty verdict after a bench trial.
In State v. Swanson, Duane Swanson was convicted in family court of two misdemeanor counts of violating a protective order by contacting the complaining witness, including in-person contact and multiple telephone messages. Swanson appealed, arguing that his constitutional right to a public trial was violated when the jury deliberated and returned its verdict after courthouse business hours when the building was closed to the public. The Hawaii Intermediate Court of Appeals affirmed the convictions, holding that the after-hours proceedings did not constitute a closure implicating the Sixth Amendment because the closure was inadvertent, there was no timely objection, and the limited circumstances did not undermine the values served by a public trial such as ensuring fairness and discouraging perjury. The court distinguished this situation from cases involving intentional courtroom closures and found that Defendant was present and the proceedings were otherwise recorded.
In this case, the defendant was convicted in district court of driving under the influence of alcohol while under the age of twenty-one and found liable for driving without headlights after a traffic stop at a DUI roadblock. The sole issue on appeal was whether the breath alcohol test result from an Intoxilyzer 5000EN should have been admitted into evidence, with the defendant arguing insufficient foundation due to lack of strict compliance with Department of Health rules on instrument approval. The court rejected the argument for strict compliance, holding that the rules integrate federal model specifications and allow for written approvals by the DUI coordinator, and that prior precedents did not impose such a requirement. It concluded that the district court did not abuse its discretion in admitting the test result and affirmed the judgments.
The case involved a workers' compensation claimant who sued her employer's insurer for bad faith after the insurer's settlement offer included a requirement that she resign her position in exchange for additional payment to close the entire claim. The court ruled that including a resignation term in a settlement offer does not amount to bad faith per se and that summary judgment for the insurer was appropriate. The court found that the claimant failed to present evidence supporting her allegations of bad faith conduct by the insurer, such as violations of insurance statutes or improper negotiation practices. The underlying dispute arose from two work-related injuries and the insurer's October 2001 settlement proposal based on medical evaluations rating her impairments.
