State v. Woods

CourtHawaii Intermediate Court of Appeals
DecidedAugust 27, 2025
DocketCAAP-24-0000030
StatusPublished

This text of State v. Woods (State v. Woods) 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. Woods, (hawapp 2025).

Opinion

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

Electronically Filed Intermediate Court of Appeals CAAP-XX-XXXXXXX 27-AUG-2025 07:50 AM Dkt. 93 SO

NO. CAAP-XX-XXXXXXX

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

STATE OF HAWAI‘I, Plaintiff-Appellee, v. WILLIAM DEL MICHAEL WOODS, also known as Smokey, Defendant-Appellant

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

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

Defendant-Appellant William Del Michael Woods (Woods) challenges his attempted murder conviction, on grounds of trial evidentiary errors and insufficient evidence to support his conviction. We affirm. Woods appeals from the January 12, 2024 "Judgment of Conviction and Sentence" (Judgment), entered by the Circuit NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

Court of the First Circuit (Circuit Court). 1 Woods was charged via Indictment with second degree attempted murder against Complainant Jimmy Vaiagae (Complainant), for a May 12, 2021, 5:46 a.m. incident, in which Complainant was doused with an accelerant and set on fire while he was sleeping (charged incident), allegedly by Woods, near the Longs Drugs store off of the Pali Highway in Honolulu. Following a 2023 jury trial, Woods was convicted as charged, and sentenced to a life term of imprisonment with the possibility of parole. On appeal, Woods raises four points of error, contending that the Circuit Court erred by: (1) ruling that a similar incident that occurred 2.5 hours before the 5:46 a.m. charged incident (3:13 a.m. incident), 2 was "probative of any other fact that was of consequence" and that "its probative value outweighed its prejudicial effect"; (2) denying Woods's "motion for mistrial" for the admission of Honolulu Police Department (HPD) Officer Brandon Goda's (Officer Goda) lay opinion testimony identifying Woods in the surveillance video of the 3:13 a.m. incident; (3) "allowing the purported expert opinion testimony" of a fingerprint examiner; and (4) convicting Woods despite the "lack of substantial evidence to support [the] conviction." 3

1 The Honorable Kevin A. Souza presided.

2 The 3:13 a.m. incident involved a male, identified as Woods by a civilian eyewitness, wearing a black tank top and black shorts, allegedly throwing a Molotov cocktail and a burning rag toward Complainant while Complainant was sleeping; the surrounding area around Complainant igniting, but not Complainant; Woods leaving the scene; and Complainant going back to sleep.

3 We have numbered Woods's points of error "A" through "D." See Hawaiʻi Rules of Appellate Procedure (HRAP) Rule 28(b)(4) (requiring "numbered" points of error). 2 NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

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, we resolve Woods's contentions as follows. (1) The evidence of the 3:13 a.m. incident Woods argues that the evidence of the 3:13 a.m. incident was inadmissible "bad character" evidence and not relevant under Hawai‘i Rules of Evidence (HRE) 404(b) 4 because it "was not probative of any other fact that was of consequence." Even if relevant, Woods argues that the evidence should have been excluded as prejudicial, "unnecessary and cumulative" under HRE Rule 403. The State points to State's Exhibits 23 and 24, 5 the surveillance videos of the 3:13 a.m. incident and the charged incident, and responds that the 3:13 a.m. incident aided in identifying Woods as the perpetrator of the charged incident and in proving Woods's intent to kill Complainant. "'Prior bad act' evidence under HRE Rule 404(b) is admissible when it is 1) relevant and 2) more probative than prejudicial." State v. Behrendt, 124 Hawai‘i 90, 102, 237 P.3d 1156, 1168 (2010) (cleaned up). We review the trial court's determination of relevance under HRE Rule 401 "under the right/wrong standard of review." Id. (citation omitted). "However, a trial court's balancing of the probative value of

4 HRE Rule 404(b) prohibits the admission of "[e]vidence of other crimes, wrongs, or acts" (prior bad acts) to prove character, but such evidence may be admissible if other probative value is shown, "such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, modus operandi, or absence of mistake or accident."

5 Exhibit 23 was a surveillance video of the 3:13 a.m. incident. Exhibit 24, the surveillance video of the charged incident at 5:46 a.m., showed an individual wearing a hoodie and a mask, carrying a torch and a cup. The individual poured the liquid from the cup onto Complainant, who was sleeping, and then used the torch to light Complainant on fire. 3 NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

prior bad act evidence against the prejudicial effect of such evidence under HRE Rule 403 is reviewed for abuse of discretion." Id. (ellipses and citation omitted). Under HRE Rule 403, relevant evidence "may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice[.]" The Behrendt court explained that when weighing the probative value versus the prejudicial effect of prior bad act evidence under HRE Rule 404(b), the court must consider various factors, 6 which include the ones the Circuit Court referenced here: "the similarities between the crimes" and "the interval of time that ha[d] elapsed between the crimes[.]" Id. at 106, 237 P.3d at 1172 (citation omitted). The record reflects that in conducting its balancing under HRE Rule 403, the Circuit Court considered the similarities between the prior bad act and the current offense, and the time interval between the two; and it concluded that the 3:13 a.m. evidence was "highly relevant" for permissible purposes under HRE Rule 404(b), as follows: THE COURT: . . . As such, I think, under 404(b), the video evidence of the 3:13 a.m. incident does become -- because of the similarities of the acts . . . both the vehicle, the height, the size, the stature of the -- of the individual depicted in both videos, the similar shorts and shoes, the tattoos . . . and other body markings that were recovered, as well as the other items that were recovered from [Woods]'s vehicle, the 3:13 a.m. [incident] video does

6 The Behrendt court indicated that a trial court "must consider a variety of factors" when weighing probative value versus prejudicial effect in the context of prior bad act evidence; and these factors include:

the strength of the evidence as to the commission of the other crime, the similarities between the crimes, the interval of time that has elapsed between the crimes, the need for the evidence, the efficacy of alternative proof, and the degree to which the evidence probably will rouse the jury to overmastering hostility.

Id. at 106, 237 P.3d at 1172 (quoting State v. Renon, 73 Haw. 23, 38, 828 P.2d 1266, 1273 (1992)). 4 NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

become highly relevant, in this Court's opinion, as to perhaps motive, intent, preparation, plan, certainly identity, modus operandi, and absence of mistake or fact.

. . . .

Essentially it's -- the State's videos that they have presented show [sic] an individual twice attempting to douse the [C]omplainant with accelerant and -- and light the [C]omplainant on fire. So [sic] the similarities between the incidents are -- they're almost exactly the same.

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State v. Woods, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-woods-hawapp-2025.