State v. Abion., 478 P.3d 270

Defendant Ramoncito Abion was charged with second-degree assault after he struck a gas-station employee with a hammer, then admitted the act to police and had the hammer in his backpack.
Three court-ordered examiners found Abion fit for trial; Dr. Martin Blinder diagnosed methamphetamine-induced psychosis and opined Abion suffered long-term/permanent effects from prior meth use and may lack penal responsibility.
The State moved to preclude Dr. Blinder’s testimony, arguing HRS § 702-230’s prohibition on self-induced intoxication bars a § 704-400 lack-of-penal-responsibility defense based on drug-induced mental illness; the trial court granted the motion relying on State v. Young.
The jury convicted Abion; the ICA affirmed. Abion sought certiorari, arguing exclusion of Dr. Blinder violated his due-process right to present a complete defense.
The Hawai‘i Supreme Court held § 702-230’s self-induced-intoxication exception applies only to temporary intoxication (acts committed while under the influence), not to permanent/settled psychoses caused by prior voluntary substance use, and that excluding Dr. Blinder violated Abion’s right to present a defense.
The Court vacated the ICA judgment and remanded for proceedings consistent with its ruling.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Abion)	Held
Whether HRS § 702-230’s bar on self-induced intoxication prevents admission of expert evidence that a defendant suffers a permanent psychosis caused by past voluntary drug use and thus blocks a § 704-400 lack-of-penal-responsibility defense	Young and § 702-230 preclude any drug-induced mental-illness defense; defendant should remain responsible for acts traceable to voluntary substance use	Young did not address preexisting or drug‑aggravated permanent illness; exclusion deprived Abion of competent evidence and the jury’s fact‑finding role	The self‑induced intoxication exception covers only temporary intoxication (acts committed while under the influence). Permanent/settled psychosis from prior voluntary use may be relevant to § 704-400; exclusion of Dr. Blinder violated due process — vacated and remanded.

State v. Young, [citation="93 Hawai'i 224, 999 P.2d 230"] (Haw. 2000) (applied self‑induced intoxication bar where defendant was temporally under influence; did not decide settled‑insanity issue)
State v. Eager, [citation="140 Hawai'i 167, 398 P.3d 756"] (Haw. 2017) (discussed jury’s role in reconciling intoxication evidence with mental‑disease evidence)
State v. Glenn, [citation="148 Hawai'i 112, 468 P.3d 126"] (Haw. 2020) (recognizes lack of penal responsibility as fundamental to due process)
State v. Horn, 58 Haw. 252, 566 P.2d 1378 (Haw. 1977) (where credible evidence supports a statutory defense, issue is for the jury)
State v. Matafeo, 71 Haw. 183, 787 P.2d 671 (Haw. 1990) (due‑process right to present a complete defense)
Chambers v. Mississippi, 410 U.S. 284 (U.S. 1973) (constitutional limits on state evidentiary rules when they bar critical defense evidence)