State v. Deguair

Summary

The Hawaiʻi Supreme Court reviewed Patrick Deguair Jr.'s convictions arising from the robbery of the Aiea Cue and the kidnapping of four individuals. The court held that the kidnapping convictions merged into the robbery conviction under Hawaiʻi Revised Statutes § 701-109(1)(e), and it rejected challenges concerning prior bad-act evidence and a purportedly improper question about firearm shooting. The court vacated the lower courts' judgments and directed reinstatement of the robbery conviction, dismissal of the kidnapping convictions, and resentencing on the robbery conviction.

Holdings

1. The circuit court did not abuse its discretion in excluding most of the proposed prior-bad-act evidence concerning Teo and Woo because the evidence was either irrelevant to Deguair's duress defense or too attenuated from the issue of whether Teo coerced Deguair into participating in the robbery.
2. The circuit court did not abuse its discretion by denying a mistrial after the prosecutor asked Deguair whether he and Teo had shot guns at the Koko Head range.
3. Under HRS § 701-109(1)(e), the kidnapping convictions merged into the robbery conviction because the jury found that the kidnappings were part of an uninterrupted continuous course of conduct directed toward the single criminal goal of robbing the Aiea Cue.

Questions Presented

1. Whether the circuit court abused its discretion by excluding certain prior-bad-act evidence concerning Deguair's alleged co-participants as too attenuated from his duress and choice-of-evils defenses.
2. Whether the circuit court abused its discretion by denying Deguair's motion for a mistrial after the prosecutor asked whether Deguair and Teo had shot guns at a shooting range.
3. Whether HRS § 701-109(1)(e) required the kidnapping convictions to merge into the robbery conviction where the jury found that the offenses were part of a continuous course of conduct committed with one general intent.
4. Whether the ICA erred by remanding solely for resentencing on the kidnapping conviction and by treating the prosecution as having the authority to choose which merged conviction would be dismissed.

Disposition

vacated