State v. Puaoi

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that “geographical facts, such as whether a particular* address is within a certain city and county of the state, is a proper matter subject to judicial notice” (internal quotation marks and citations omitted)
• noting that “appellate courts may take judicial notice of venue, provided that the requirements of HRE 201(b) are met”
• noting that HRS § 701-114(l)(d) requires that venue be proved beyond reasonable doubt in order to sustain conviction
• stating that “[t]hough mindful that this power to deal with error is one to be exercised sparingly[,]” “where plain error has been committed and substantial rights have been affected thereby, the error may be noticed” (quotation marks and citations omitted)
• \A conviction based on insufficient evidence of any element of the offense charged is a violation of due process and thus constitutes plain error.\
• on appeal, judicial notice taken, in reliance on published atlas, of fact that particular highway was located entirely within Moloka'i district of second judicial circuit, thus proving facts establishing venue beyond a reasonable doubt

Source: CourtListener parenthetical corpus (CC0).