State v. Garces, Jr. ICA s

Summary

The Hawaiʻi Supreme Court held that article I, section 10 of the Hawaiʻi Constitution requires law enforcement, in addition to the four traditional Miranda warnings, to expressly advise custodial suspects that they may cease answering questions and request an attorney at any time. Because the rule is new, the court gave it purely prospective effect, effective October 23, 2026, so it did not govern Garces's interrogation. Applying then-existing law, the court held Garces knowingly, intelligently, and voluntarily waived his Miranda rights despite suicidal ideation and mental distress, and affirmed his second-degree murder conviction, sentence, and the ICA's judgment. The court also clarified that suicidal ideation does not require corroborating action, deeming the circuit court's contrary conclusion of law clear but harmless error.