Hawaii Supreme Court · 2000
State v. Jenkins
At a night stop in a deserted area, the passenger dropped apparent ice packets and jumped out against orders, and both occupants kept moving. Probable cause plus an officer-safety emergency let the officer seize a closed pouch from the seat without a warrant, and a gun he then saw in plain view.
997 P.2d 13
Find the opinion for State v. JenkinsHawaii Supreme Court · 2009
State v. Estabillio
An investigative detention must be reasonably related in scope to the circumstances that justified it at its inception; a separate, unrelated drug investigation launched during a valid traffic stop is an independent seizure requiring its own reasonable suspicion, and evidence from an unsupported drug investigation is suppressed as fruit of the poisonous tree (conviction reversed).
218 P.3d 749
Find the opinion for State v. EstabillioHawaii Supreme Court · 2009
State v. Wheeler
Driving or being in physical control 'upon a public way, street, road, or highway' is an element of OVUII. An oral charge saying only that Wheeler 'operated' a vehicle, challenged before trial, did not give fair notice of that element, and the case was dismissed without prejudice.
219 P.3d 1170
Find the opinion for State v. WheelerEach summary was checked against the court’s majority opinion on September 30, 2026. Read the decision and follow your agency’s policy; this is reference guidance, not legal advice.