This case involved an appeal from a conviction for driving under the influence (DUI) under Hawaii law, where the defendant argued that delays in the trial violated his right to a speedy trial and required dismissal under HRPP Rule 48(b), which sets a six-month limit for non-traffic offenses. The court held that DUI is classified as a traffic offense under HRS Chapter 291, so the six-month dismissal rule does not apply, despite DUI being a serious offense that allows for a jury trial. Regarding the constitutional speedy trial claim, the court found no violation because the defendant failed to show any prejudice from the delay, applying the factors from Barker v. Wingo. The conviction was affirmed.

criminal lawprocedure

The case involved a dispute among the trustees of the Bernice Pauahi Bishop Estate over the acquisition of an interest in the Kawaiaha'o Plaza office building as a replacement for offices lost to eminent domain. The circuit court found it lacked authority to review the transaction's propriety because fewer than all trustees had sought instructions, yet it still examined the deal, identified an ongoing dispute, and directed the Attorney General to issue instructions to the trustees. On appeal, the Hawaii Supreme Court held that the circuit court erred by subjecting the trustees' discretionary conduct to judicial scrutiny and ordering a specific course of action. The core reasoning was that a court cannot adjudicate the rights or conduct of trustees without all necessary parties properly before it seeking relief, as reflected in both the procedural posture and precedents on equitable jurisdiction over trust matters.

propertyprocedurebusiness & regulatory