State v. Silva
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In a case before the Supreme Court of Hawaii, the defendant, Kumulipo Iwa Coyote Sylva, was charged with second-degree murder for killing Eduardo Alejandro Cerezo. Sylva admitted to the killing but asserted the affirmative defense of insanity. In a jury trial, three medical examiners testified regarding Sylva's mental state at the time of the killing. Two of the examiners opined that Sylva lacked capacity due to a mental disease, disorder, or defect, thus excluding criminal responsibility. However, parts of the testimony of one of these examiners were struck by the circuit court. Sylva was ultimately convicted of manslaughter based on extreme mental or emotional disturbance (EMED).
The Supreme Court of Hawaii held that the circuit court erroneously struck parts of the examiner's testimony which should have been admitted to clarify his opinion under Hawai‘i Revised Statutes § 704-410(4). The court found that a reasonable juror could have believed the circuit court instructed them to disregard the examiner's entire answer explaining his opinion that Sylva lacked capacity under the legal standard for insanity. The error was not harmless beyond a reasonable doubt because Sylva's insanity defense turned largely on the medical examiners’ testimonies. Therefore, the court vacated the circuit court’s judgment, conviction, and sentence, as well as the Intermediate Court of Appeal’s judgment on appeal, and remanded the case to the circuit court for further proceedings.
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