State v. Kato
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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the judgment of the circuit court convicting Defendant of reckless endangering in the second degree, holding that the circuit court erred by excluding Defendant from presenting third-party culpability evidence at trial.
In precluding Defendant from presenting third-party culpability evidence the circuit court determined that the evidence failed to establish a "legitimate tendency" that the third party committed the crime. The Supreme Court vacated Defendant's conviction, holding (1) admissibility of third-party culpability evidence is properly governed by Haw. R. Evid. 401 and 403, without having also to satisfy a legitimate tendency test; (2) the circuit court erred in precluding the defense from adducing third-party culpability evidence that another person assaulted the complaining witness; and (3) the circuit court and the ICA improperly weighed the third-party culpability evidence offered by Defendant.
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