Hawai'i Legal News

  State v. Spies (HSC September 16, 2025). Jonathan Spies was stopped by the police as he stepped out of his truck in the Foodland parking lot in Waimea on the Big Island. Sierra Valderrama was in the passenger seat. The officer had him sit in the back of his pickup while backup showed up. When they did, they told Spies they had a warrant to search his person —and nothing else. They did not have a warrant to search the vehicle.   They executed the warrant and had Valderrama get out of the truck. The police found nothing on Spies. Officer Justin Gaspar asked Spies if he could search his truck. Spies did not respond with a “yes” or “no” answer. He said something to the effect of “it’s all in there” or “everything that you guys are looking for is in there.” Officer Gaspar asked him  to clarify what he meant and Spies said that it was in his wallet. Spies did not consent to a search of the truck. The police held him for another three minutes after executing the warrant. T...

  State v. Yuen (HSC August 20, 2024) Background. Charles Tung Ming Yuen was charged with driving under the influence of an intoxicant. The charge arose from a motor vehicle collision that occurred approximately fifty feet from the O’Malley Gate just outside of the Joint Base Pearl Harbor-Hickam in Honolulu. Two vehicles were approaching the gate when one of the vehicle rear-ended the one in front of it. Military police came onto the scene and identified Yuen as the driver of the vehicle that cause the collision. They seized him and subjected him to standardized field sobriety tests. Then they held him and called the Honolulu Police Department to report a “possible DUI outside the gate.”   The collision, seizure of Yuen, and their investigation occurred outside of the base within the City and County of Honolulu. The police showed up and took over. They conducted their investigation, saw signs of intoxication, and arrested Yuen.   Yuen’s lawyer, Barry Sooalo, di...

  Deangelo v. Souza (HSC November 17, 2022) Background. Scott Deangelo arrested without a warrant for second-degree murder. The district court made a judicial determination of probable cause the next day. The prosecution filed a complaint alleging murder and held a preliminary hearing. At the hearing, the district court found probable cause based on the evidence presented and committed the case to the circuit court. The prosecution did not present evidence before a grand jury and no true bill of indictment issued.   Instead, the prosecution filed a complaint in the circuit court. Deangelo pleaded not guilty and filed a motion to dismiss on the grounds that because he was not indicted, the prosecution violated HRS § 801-1. While that motion was pending, the HSC issued its decision in State v. Obrero , 151 Hawai'i 472, 517 P.3d 755 (2022). The prosecution conceded the violation and requested that Deangelo remain in custody without bail so it could indict him. The circuit ...

  State v. Keanaaina (HSC March 22, 2022).  Background. Police get a warrant to search Michelle Wright’s tent at an encampment inside the Old Kona Airport Park on the Big Island. The warrant authorized the police to search her campsite and “all rooms, boxes, toolboxes, suitcase, handbags, safes, backpacks, fanny packs, bags, storage containers” and other enclosed things in the camp. The officers get to the camp sight and announce their presence asking everyone to get out of their tents. There were seven separate sites at the time. There was no obvious entrance or exit for Wright’s camp sight, but officers were able to get into the tent without moving materials that formed its walls.   Detective Michael Hardie looked into the tent and saw Wright and Samson Keanaaina asleep on a mattress. He again announced his presence. Wright woke up and got out through an opening on one end of the structure. Keanaaina slept through the police shouting at him. Wright explained he was h...

  State v. Willis (HSC December 2, 2021) Background. Erik Willis was indicted for attempted murder in the second degree. Willis moved to suppress evidence gathered by the police when they went into his house and arrested him without a warrant. The police suspected Willis of repeatedly stabbing a teenager without provocation on a beach in Kahala. They surveilled him for a day and a half and concluded they had probable cause to make the arrest.   The officers went into his house to arrest him without a search or arrest warrant. When they went inside, they saw shoes and a shirt that matched the description from an eyewitness to the stabbing. The circuit court, the Hon. Judge Kevin Souza presiding, granted the motion and excluded evidence of the shoes, shirt, and Willis’s statements. The prosecution appealed and the case was transferred to the HSC.   Search and Seizure: the Basics. “The right of the people to be secure in their persons, houses, papers, and effects,...

  Caniglia v. Strom (SCOTUS May 17, 2021) Background. Edward Caniglia was arguing with his wife at home in Rhode Island. He took a handgun from the bedroom, put it on the dining room table, and told his wife to “shoot [him] now and get it over with.” She left the house and checked into a hotel. When he did not answer the phone the next day, she called the police to conduct a welfare check at the house. She went home with the police and saw Caniglia was still alive and did not want to go to the hospital for a psychiatric examination. He was eventually coaxed out and made the police promise that they would not take away his guns. After he left the house, the police went inside the residence and confiscated two handguns.   Caniglia sued the police on the grounds that they violated his Fourth Amendment rights. The District Court granted summary judgment for the police and it was affirmed by the United States Court of Appeals First Circuit. The SCOTUS took certiorari. ...