State v. Doo — Hawaii Supreme Court rejects certiorari, leaving ICA ruling intact

Case
State of Hawaiʻi v. Owen D. Doo
Court
Supreme Court of Hawaiʻi
Date Decided
June 25, 2026
Docket No.
SCWC-24-0000828
Topics
Criminal law, Certiorari, Appellate procedure

Background

Owen D. Doo was the defendant in a criminal case originating in the First Circuit Court of Hawaiʻi (Case No. 1PC051001262). After an adverse ruling at the trial level, Doo appealed to the Hawaiʻi Intermediate Court of Appeals (ICA), which docketed the matter as CAAP-24-0000828. The ICA’s disposition was unfavorable to Doo, prompting him to seek further review from the Hawaiʻi Supreme Court.

On April 30, 2026, Doo filed an Application for Writ of Certiorari asking the Supreme Court of Hawaiʻi to review the ICA’s decision. The five-justice panel — Chief Justice Devens, Justices McKenna, Eddins, and Ginoza, and Circuit Judge Drewyer sitting by assignment due to a vacancy — considered the application.

The Court’s Holding

The Supreme Court of Hawaiʻi rejected Doo’s Application for Writ of Certiorari by order dated June 25, 2026. The court provided no written opinion explaining its reasons, which is typical when certiorari is denied; the rejection is a discretionary determination that the court will not take up the case.

The rejection leaves the ICA’s ruling as the final appellate disposition of the matter. All five members of the panel joined in the order.

Key Takeaways

  • The Hawaiʻi Supreme Court declined to review the ICA’s decision against Doo, ending his appellate options within the state court system.
  • A rejection of certiorari is not a ruling on the merits; it simply means the Supreme Court chose not to exercise its discretionary review.
  • The ICA’s decision in CAAP-24-0000828 stands as the controlling appellate authority in this case.

Why It Matters

While a certiorari rejection carries no precedential weight on the underlying legal questions, it signals the conclusion of Doo’s direct state appellate proceedings. Any further challenge would require pursuing post-conviction relief or, if a federal constitutional issue is implicated, seeking review in the federal courts.

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