State v. Woody

Summary

The Hawaiʻi Supreme Court held that the Intermediate Court of Appeals (ICA) erred by applying its Lee test to a State motion to continue a suppression hearing based on witness unavailability, and it rejected the Lee test in its entirety—including for State motions—as unworkable and fundamentally unfair. The court announced a new framework: a State continuance request is first analyzed for HRPP Rule 48 excludability under Rule 48(c)(4)(i)'s due diligence standard; if diligence is lacking, Gillis bars exclusion under Rule 48(c)(8), but if the Rule 48 deadline has not expired the court must decide the request under a common law good cause standard weighing the totality of circumstances. Applying that framework, the court upheld the district court's lack-of-due-diligence finding but held good cause existed for a reasonable continuance, affirmed the ICA's judgment vacating the suppression order on different grounds, and remanded to the district court.