State v. Gonzalez
Annotate this CaseDefendant was charged with excessive speeding in violation of Haw. Rev. Stat. 291C-105(a). After the charge was read, Defendant moved to dismiss the charge, arguing that it failed to state the requisite state of mind under Haw. Rev. Stat. 702-204. The court denied Defendant's motion, ruling that when a statute does not expressly set forth the culpable state of mind, but rather imports the mens rea element from Haw. Rev. Stat. 702-212 that obviated the need of the State to articulate a state of mind. The district court subsequently convicted Defendant of the charge. The Supreme Court vacated the judgment and instructed the district court to dismiss the charge without prejudice, holding (1) the offense of driving at an excessive speed is not a strict liability offense and requires proof that the defendant acted intentionally, knowingly, or recklessly, an thus, the requisite states of mind must be alleged in a charge of this offense; (2) the section 291C-105(a) charge against Defendant failed to allege the requisite states of mind; and (3) the State also failed to lay an adequate foundation to admit a laser instrument reading of Defendant's vehicle's speed into evidence.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.