State v. Garces, Jr. ICA s

Summary

The court affirmed Garces’s murder conviction and sentence, holding that Hawaiʻi’s Constitution requires an express warning that a custodial suspect may stop questioning and request an attorney at any time. Because that rule is new and applies only prospectively, it did not govern Garces’s interrogation; under the existing four-warning framework, he knowingly, intelligently, and voluntarily waived his rights despite suicidal ideation and mental distress. The court also held that the circuit court’s erroneous credibility conclusion concerning Garces’s suicidal statements was harmless.