State v. Voorhees
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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the district court's judgment finding Defendant guilty of resisting arrest, holding that Defendant was entitled to relief on his claim that his waiver of his right to a jury trial was not knowing, intelligent, and voluntary.
Defendant signed a waiver form purporting to waive his right to a jury trial on the charge of resisting arrest. The district court accepted the waiver. After a bench trial, the court found Defendant guilty of resisting arrest and several other charges. The ICA affirmed. The Supreme Court vacated the judgments of the lower courts, holding (1) the record did not reflect a discuss and exchange sufficient to satisfy the district court's responsibility of ensuring a jury trial waiver's validity; and (2) under this Court's recent decision in State v. Ernes, 465 P.3d 763 (Haw. 2020), Defendant's waiver was not properly verified as knowing, intelligent and voluntary.
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