Background
Scott David Deangelo was a criminal defendant in two consolidated cases in the First Circuit Court of Hawaiʻi (Case Nos. 1CPC-22-0001357 and 1CPC-23-0000307). After proceedings at the trial level, the matter was appealed to the Intermediate Court of Appeals (ICA) under CAAP-24-0000509.
Following the ICA’s disposition in Deangelo’s favor — or otherwise adverse to the State — the State of Hawaiʻi, as petitioner, sought further review by filing an Application for Writ of Certiorari with the Hawaiʻi Supreme Court on May 29, 2026, asking the court to examine the ICA’s ruling.
The Court’s Holding
The Hawaiʻi Supreme Court, in a brief order issued July 6, 2026, rejected the State’s Application for Writ of Certiorari. The order was unanimous, signed by Chief Justice Devens along with Justices McKenna, Eddins, and Ginoza, and Circuit Judge Nakamoto sitting by assignment due to a court vacancy.
By rejecting the application, the court declined to exercise discretionary review of the ICA’s decision, leaving the ICA’s ruling as the final appellate disposition in the case.
Key Takeaways
- The Hawaiʻi Supreme Court rejected — not merely denied — the State’s certiorari petition, ending the State’s appellate pursuit in this criminal matter.
- The ICA’s decision below stands as the controlling appellate ruling.
- The order was unanimous among all five justices participating, including one circuit judge sitting by assignment due to a court vacancy.
Why It Matters
While the Supreme Court’s rejection order contains no written analysis, its refusal to grant certiorari signals that the court found no compelling reason to revisit the ICA’s ruling — whether on grounds of legal error, conflicting precedent, or significant public interest. The ICA decision therefore remains binding on the parties.
Practitioners should note that in Hawaiʻi, certiorari to the Supreme Court from the ICA is discretionary. A rejection order of this kind carries no precedential weight on the merits, but it does confirm the finality of the ICA’s outcome for the defendant.