Guity v. State

CourtHawaii Supreme Court
DecidedMarch 31, 2025
DocketSCWC-21-0000531
StatusPublished

This text of Guity v. State (Guity v. State) is published on Counsel Stack Legal Research, covering Hawaii Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guity v. State, (haw 2025).

Opinion

***NOT FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER***

Electronically Filed Supreme Court SCWC-XX-XXXXXXX 31-MAR-2025 09:43 AM Dkt. 47 SO

SCWC-XX-XXXXXXX

IN THE SUPREME COURT OF THE STATE OF HAWAII ________________________________________________________________

WALTER N. GUITY, Petitioner/Petitioner-Appellant,

vs.

STATE OF HAWAIʻI, Respondent/Respondent-Appellee. ________________________________________________________________

CERTIORARI TO THE INTERMEDIATE COURT OF APPEALS (CAAP-XX-XXXXXXX; CIVIL NO. 1CCV-XX-XXXXXXX)

SUMMARY DISPOSITION ORDER (By: Recktenwald, C.J., McKenna, Eddins, and Devens, JJ., and Circuit Judge Cataldo in place of Ginoza, J., recused)

Petitioner Walter N. Guity filed a petition in the

Circuit Court of the First Circuit (circuit court) under Hawai‘i

Revised Statutes (HRS) chapter 661B (2016) for redress for

wrongful conviction and imprisonment related to two vacated

convictions of sexual assault. The circuit court, 1 upon a motion

from the Respondent State of Hawai‘i, dismissed Guity’s petition

as to both convictions. Guity appealed, and the Intermediate

1 The Honorable Jeffrey P. Crabtree presided. ***NOT FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER***

Court of Appeals (ICA) held that “Guity’s petition satisfied the

pleading requirements of HRS § 661B-1(b)(1) as to one of his

convictions, but not the other.” Guity v. State, 153 Hawai‘i

368, 370, 538 P.3d 780, 782 (App. 2023) (Guity III). At the

time of Guity’s application for writ of certiorari, this court

had not yet adjudicated the pleading requirements of HRS

§ 661B-1(b)(1) (2016). Having recently done so in Jardine v.

State, 155 Hawai‘i 60, 556 P.3d 406 (2024), we now affirm the

ICA’s holding in the instant case.

On May 18, 2011, Guity entered a global plea agreement

in the circuit court related to criminal charges in two separate

cases, one in the family district court (family court case) and

the other in the circuit court (circuit court case). The

charges in the two cases arose from separate incidents of

alleged sexual assault. The facts in the underlying criminal

cases are recited in State v. Guity, 139 Hawai‘i 272, 398 P.3d

901, 2016 WL 6427681, at *2 (App. Oct. 31, 2016) (mem. op.)

(Guity I) and State v. Guity, 144 Hawai‘i 557, 445 P.3d 138

(2019) (Guity II).

As part of the plea agreement, Guity pleaded guilty to

second-degree sexual assault in the circuit court case and

third-degree sexual assault in the family court case. Guity II,

144 Hawai‘i at 559, 445 P.3d at 140. The complaining witness in

the family court case was Guity’s spouse. Id. at 558-59, 2 ***NOT FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER***

445 P.3d at 139-40. At the time of Guity’s guilty plea, an

offense against one’s spouse was expressly excluded from the

offense of third-degree sexual assault. See HRS § 707-732(1)(f)

(Supp. 2009); HRS § 707-700 (Supp. 2009). Thus, it was legally

impossible for Guity to have committed the offense to which he

pleaded guilty in the family court case. Guity I, 2016 WL

6427681, at *8.

Subsequent to his plea, Guity became dissatisfied with

his attorney, who ultimately withdrew as Guity’s counsel. Guity

II, 144 Hawai‘i at 559, 445 P.3d at 140. Proceeding pro se

before the circuit court, Guity orally moved to withdraw his

guilty pleas in both cases. Id. The circuit court denied

Guity’s motion and, pursuant to the plea agreement, sentenced

him to concurrent terms of twelve months of imprisonment in the

family court case and eighteen months of imprisonment in the

circuit court case. Id. at 560, 445 P.3d at 141.

Guity appealed his convictions. This court held that

Guity should have been allowed to withdraw his guilty plea in

the family court case because “the Circuit Court definitively

knew that it was legally impossible for Guity to have committed”

the offense of third-degree sexual assault against his spouse.

Id. at 562-63, 445 P.3d at 143-44 (citation omitted). Further,

because the pleas in both cases were part of a single agreement,

we held that Guity “was entitled to withdraw his plea in the

3 ***NOT FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER***

circuit court case.” Id. at 563, 445 P.3d at 144. Accordingly,

we remanded to the circuit court for further proceedings with

instructions to accept Guity’s withdrawal of both pleas. Id. at

563-64, 445 P.3d at 144-45. By that time, however, Guity had

already served the entirety of his concurrent sentence. Both

cases were ultimately dismissed on remand. Guity III, 153

Hawai‘i at 370-71, 538 P.3d at 782-83.

On May 14, 2021, Guity filed a civil petition in

circuit court seeking redress for wrongful conviction and

imprisonment under HRS chapter 661B. The State moved to dismiss

his petition on the grounds that Guity failed to meet the

pleading requirements of HRS § 661B-1(b)(1), which require a

petitioner to allege that they were “actually innocent” of the

crimes for which they were convicted. 2 The circuit court granted

the State’s motion to dismiss. Guity appealed.

2 HRS § 661B-1(b) provides:

(b) To present an actionable claim against the State for wrongful conviction and imprisonment, the petitioner shall allege that the petitioner was convicted of one or more crimes under the laws of the State, was subsequently sentenced to a term of imprisonment, and has served all or any part of the sentence and either that: (1) The judgment of conviction was reversed or vacated because the petitioner was actually innocent of the crimes for which the petitioner was convicted, and the court decision so states; or (2) The petitioner was pardoned because the petitioner was actually innocent of the crimes for which the petitioner was convicted and the pardon so states.

(Emphasis added).

4 ***NOT FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER***

On appeal, the ICA held that Guity’s petition

satisfied the pleading requirements as to the family court case

but not the circuit court case. Guity III, 153 Hawai‘i at 376-

77, 538 P.3d at 788-89. Reviewing the appellate court decisions

that had vacated Guity’s family court conviction, the ICA

acknowledged that Guity I stated “there was no factual basis

(because the complaining witness was Guity’s wife) or legal

basis (because the definition of ‘sexual contact’ excluded

contact with the defendant’s spouse) for Guity’s conviction.”

Id. at 376, 538 P.3d at 788. Further, Guity II “noted it was

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Bluebook (online)
Guity v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guity-v-state-haw-2025.