State v. Casugay-Badiang

Summary

The Hawai‘i Supreme Court considered whether a sentencing court could sentence a defendant convicted of second-degree methamphetamine trafficking under the young adult defendants statute, HRS § 706-667, rather than under the specific sentencing provision in HRS § 712-1240.8. The court held that the “notwithstanding ... any other law to the contrary” language in HRS § 712-1240.8 did not preclude sentencing under HRS § 706-667. It reversed the Intermediate Court of Appeals and affirmed the circuit court’s judgment and order denying the State’s motion to correct the sentence.

Holdings

1. The sentencing court retained discretion to sentence a qualifying young adult defendant under HRS § 706-667 after a conviction for second-degree methamphetamine trafficking under HRS § 712-1240.8.
2. Because the relationship between HRS § 712-1240.8(3) and HRS § 706-667 was ambiguous, the rule of lenity required resolving the ambiguity in favor of the defendant.
3. The circuit court's concurrent five-year indeterminate terms under HRS § 706-667 were permissible, and its judgment of conviction and sentence and order denying the motion to correct illegal sentence were affirmed.

Questions Presented

1. Whether the phrase "Notwithstanding sections 706-620, 706-640, 706-641, 706-660, 706-669, and any other law to the contrary" in HRS § 712-1240.8(3) precludes sentencing a qualifying defendant under HRS § 706-667.
2. Whether the rule of lenity resolves the ambiguity between HRS § 712-1240.8(3) and HRS § 706-667 in favor of allowing young-adult-defendant sentencing.
3. Whether the circuit court retained discretion to impose a special five-year indeterminate term under HRS § 706-667 after a conviction for second-degree methamphetamine trafficking.

Disposition

reversed