State v. Means
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The Supreme Court vacated Defendant's sentence for theft in the second degree by shoplifting, holding that, pursuant to State v. Auld, 361 P.3d 471 (Haw. 2015), Defendant's sentence violated his right to a jury determination as to whether he qualified to be sentenced as a repeat offender pursuant to Haw. Rev. Stat. 706-606.5.
The circuit court sentenced Defendant as a repeat offender to a mandatory minimum of five years' incarceration without the possibility of parole. The circuit court, however, did not require a jury to find that Defendant qualified as a repeat offender beyond a reasonable doubt, as required by Auld. The intermediate court of appeals (ICA) affirmed the conviction and sentence. The Supreme Court vacated the ICA's judgment on appeal and the circuit court's sentence and remanded the case for resentencing, holding (1) Defendant was entitled to the protections of Auld; and (2) the State was required to, but did not, prove Defendant's predicate prior convictions to a jury beyond a reasonable doubt prior to imposition of a mandatory minimum sentence as a repeat offender.
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