State v. Sardinha
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The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) determining that Hawai'i law did not require the joinder of Defendant's traffic offenses with his assault offense, holding that the ICA did not err.
Defendant was charged with two separate sets of offenses - traffic offenses and an assault offense - that he argued arose from a single criminal episode. Defendant filed a motion to dismiss, arguing that Haw. Rev. Stat. 701-109 required the State to try the traffic offenses and the assault offense together. The circuit court granted the motion to dismiss. The ICA vacated the circuit court's order, holding that the traffic offenses and the assault offense were not so closely related in time, place, or circumstances that section 701-109(2) compelled the joinder of the two proceedings. The Supreme Court affirmed, holding that Hawai'i law did not require joinder under the circumstances.
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