Justia Juvenile Law Opinion Summaries

Articles Posted in Supreme Court of Hawaii
by
The Supreme Court reversed the ruling of the family court that the prosecution had proven that DM, a minor who stabbed another minor, had committed attempted assault in the first degree beyond a reasonable doubt, holding that the family court inadequately assessed the circumstances from DM's perspective in rejecting DM's self-defense defense.After a bench trial, during which DM argued that he lacked intent and acted in self-defense, the family court adjudicated DM as having committed attempted assault in the first degree. DM appealed, challenging the court's self-defense-related findings and conclusions. The Supreme Court reversed, holding (1) the family court wrongly rejected DM's defense by inadequately assessing his conduct from his perspective and by misapplying key self-defense elements; and (2) there was not substantial evidence to support the family court's conclusion that the State proved beyond a reasonable doubt that DM's use of deadly force was unjustified. View "In re DM" on Justia Law

by
The Supreme Court vacated the order of the intermediate court of appeals (ICA) affirming the judgment of the family court adjudicating Minor as a law violator for sexually assaulting the nine-year-old complaining witness (CW), holding that the exclusion of certain evidence proffered in this case was not harmless beyond a reasonable doubt.On appeal, Minor argued that the family court erred in excluding his proffered extrinsic evidence of CW's past false sexual assault allegations and by failing to make a preliminary determination as to the truth or falsity of those past sexual assault allegations. The Supreme Court vacated the ICA's judgment on appeal and the family court's decree, holding (1) if a defendant seeks to admit a complaining witness's false allegations of sexual assault, admissibility of such evidence is not subject to Haw. R. Evid. 412; and (2) the family court abused its discretion by excluding the proffered evidence based on the procedural requirements of Rule 412. View "In re GH" on Justia Law