State v. Pulliam

541 P.3d 665, 153 Haw. 445
CourtHawaii Intermediate Court of Appeals
DecidedJanuary 26, 2024
DocketCAAP-21-0000678
StatusPublished

This text of 541 P.3d 665 (State v. Pulliam) is published on Counsel Stack Legal Research, covering Hawaii Intermediate Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Pulliam, 541 P.3d 665, 153 Haw. 445 (hawapp 2024).

Opinion

NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER

Electronically Filed Intermediate Court of Appeals CAAP-XX-XXXXXXX 26-JAN-2024 08:25 AM Dkt. 183 SO

NO. CAAP-XX-XXXXXXX

IN THE INTERMEDIATE COURT OF APPEALS OF THE STATE OF HAWAI#I

STATE OF HAWAI#I, Plaintiff-Appellee, v. JOSHUA PULLIAM, Defendant-Appellee, and ISAIAH MCCOY, Defendant-Appellant

APPEAL FROM THE CIRCUIT COURT OF THE FIRST CIRCUIT (CRIMINAL NO. 1CPC-XX-XXXXXXX)

SUMMARY DISPOSITION ORDER (By: Leonard, Acting Chief Judge, Wadsworth and Nakasone, JJ.)

Defendant-Appellant Isaiah McCoy (McCoy) appeals from

the October 26, 2021 Judgment of Conviction and Sentence Notice

of Entry (Judgment) entered by the Circuit Court of the First

Circuit (Circuit Court)1 in favor of Plaintiff-Appellee, the

State of Hawai

indicted on one count of Robbery in the Second Degree in

violation of Hawaii Revised Statutes (HRS) § 708-841(1)(a)

(2014).2 On May 3, 2021, a jury found McCoy guilty as charged.

1 The Honorable James S. Kawashima presided. 2 HRS § 708-841 provides, in pertinent part:

§ 708-841 Robbery in the second degree. (1) A person commits the offense of robbery in the second degree if, in the course of committing theft or non-consensual taking of a motor vehicle: (continued...) NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER

On August 3, 2021, McCoy was sentenced to a maximum term of ten

years imprisonment and was ordered to pay restitution in the

amount of $6,256.64.

McCoy raises seven points of error on appeal,

contending that the Circuit Court: (1) abused its discretion by

increasing bail from $20,000.00 to $100,000.00, revoking bail

altogether, and denying McCoy's requests to reinstate bail while

jury trials were suspended due to the COVID-19 pandemic; (2)

erred in not suppressing field show-up evidence; (3) abused its discretion in denying McCoy's motion to dismiss his indictment

(Motion to Dismiss); (4) erred in denying McCoy's motion to allow

a key mainland witness to testify at trial virtually; (5) erred

in denying McCoy's motion for judgment of acquittal based on

insufficient evidence; (6) erred in denying McCoy's various

requests for jury instructions; and (7) abused its discretion in

sentencing McCoy to a ten-year prison term while co-defendant

Joshua Pulliam (Pulliam) was given probation.

Upon careful review of the record and the briefs

submitted by the parties, and having given due consideration to

the arguments advanced and the issues raised by the parties, we

resolve McCoy's arguments as follows:

(1) McCoy argues that the Circuit Court abused its

discretion in setting McCoy's bail at $100,000 after McCoy's

2 (...continued) (a) The person uses force against the person of anyone present with the intent to overcome that person's physical resistance or physical power of resistance[.] . . . . (2) Robbery in the second degree is a class B felony.

2 NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER

indictment,3 rather than maintaining McCoy's bail at the lower

amount that was set upon McCoy's arrest. We conclude, however,

that this issue is moot because the bail in question was revoked,

upon the State's motion, after McCoy was arrested at the airport

for attempting to flee Hawai

an October 10, 2019 evidentiary hearing, that McCoy intentionally

violated the bail condition that he may not leave the

jurisdiction.

McCoy also argues that the Circuit Court erred when it denied a motion for reinstatement of bail following a November

15, 2019 hearing. First, the premise of this argument is wrong

as it appears that his eligibility for bail was reinstated prior

to that hearing, and McCoy's complaint in fact relates to the

amount of bail he was required to post. McCoy contends that he

provided ample testimony that, although he had been arrested

while trying to board a plane to Los Angeles, he had attempted to

seek permission from his bail bondsman ahead of time. It appears

that he contends that this "attempt to seek permission" entitled

him to a lower bail. This contention is without legal support

and without merit.

In addition, McCoy contends that the Circuit Court

abused its discretion and erred because the circumstances of the

COVID-19 Pandemic warranted reinstating his bail, citing In re

Individuals in Custody of State, SPCW-XX-XXXXXXX, 2021 WL

4762901, *22 (Haw. Oct. 12, 2021) (McKenna, J., concurring and

dissenting in part). However, the Hawai#i Supreme Court in In re

3 The Honorable Shirley M. Kawamura presided.

3 NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER

Individuals in Custody of State held that, regardless of the

pandemic, trial courts retained discretion in setting bail and

imposing conditions on release and that the pandemic was not

enough to permit the release of all detainees who did not pose a

risk to public safety or flight. 2021 WL 4762901, at *4, *5. As

McCoy makes no particularized argument regarding his

circumstances during the pandemic based on the record in this

case (or otherwise), we conclude that this contention is without

merit. (2) McCoy contends that the Circuit Court erred in

denying his motion to suppress the field show-up identification

of McCoy by two witnesses.

In State v. Kaneaiakala, 145 Hawai#i 231, 450 P.3d 761

(2019), the supreme court held: A defendant is denied due process of law when the procedure used to obtain an eyewitness identification admitted at trial is unnecessarily suggestive and conducive to irreparable mistaken identification. We have held, however, that an eyewitness identification is not inadmissible merely because the identification procedure was impermissibly suggestive. Rather, whether an eyewitness identification obtained through an impermissibly suggestive procedure is admissible depends upon the reliability of the identification.

145 Hawai#i at 240, 450 P.3d at 770 (citations and internal

quotation marks omitted).

The supreme court held that trial courts must consider

the same thirteen factors as set forth for jurors (in Hawai#i

Standard Jury Instructions, Criminal (HAWJIC) 3.19)) when

evaluating the reliability of challenged eyewitness

identifications for admissibility purposes: [T]rial courts must, at minimum, consider any relevant factors set out in [HAWJIC] governing eyewitness and show-up identifications, as may be amended, as well as

4 NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER

any other relevant factors that may be set out in binding precedent in addressing whether, under a totality of circumstances, an impermissibly suggestive eyewitness or show-up identification is nonetheless sufficiently reliable to be admissible in evidence.

Kaneaiakala, 145 Hawai

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Bluebook (online)
541 P.3d 665, 153 Haw. 445, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-pulliam-hawapp-2024.