State v. Guyton.
135 Haw. 372
| Haw. | 2015Background
- John Varel obtained a 2009 injunction against Evans Guyton prohibiting "entering or visiting [Varel's] residence, including yard and garage." The injunction was on a preprinted form and ran for three years.
- Varel owns a 1,000-acre macadamia farm in Maui; his house is on one part of that property and the land includes remote ridges about a mile-plus from the highway.
- On Feb. 19, 2012, private contractor Todd Arnold saw Guyton dirt-biking on the ridges at the outer edge of Varel’s property; Guyton was later charged with violating the injunction.
- At a bench trial, the district court found the State’s witnesses credible, concluded the injunction language encompassed the area where Guyton was seen, and convicted Guyton (fine stayed pending appeal).
- The ICA affirmed. The Hawaiʻi Supreme Court granted certiorari to decide whether the phrase "residence, including yard" covers the remote portions of Varel’s 1,000-acre property and whether evidence supported the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning/scope of "residence, including yard" in the injunction | The phrase is broad; State urged ordinary meaning (and provided a dictionary) to include extensive grounds, so the entire property can be treated as the "yard." | "Yard" should have its plain, ordinary meaning—grounds immediately surrounding the house—so it does not include remote ridges of a 1,000-acre parcel. | Held: "Residence, including yard" means the house and its immediate adjacent grounds; it does not encompass the remote outer areas of the 1,000-acre property. |
| Requirement of clarity before punishing violation of an injunction | The State argued the injunction and map shown at the injunction hearing gave adequate notice of prohibited area. | Guyton argued court orders must be sufficiently particular; expansive or unclear orders should be construed for the defendant (rule of lenity). | Held: Court orders imposing criminal exposure must be clear and unambiguous; ambiguity must be resolved in favor of the defendant. |
| Sufficiency of evidence that Guyton knowingly entered prohibited area | State argued testimony showed Guyton knew Varel's property was off-limits and a map was shown at the injunction hearing, supporting knowing entry. | Guyton argued lack of fences/signs and uncertainty about boundaries negated the required mental state; even if on the property, area was outside the injunction's scope. | Held: Viewing evidence in the light most favorable to the State, the area where Guyton was seen falls outside the injunction's scope, so the conviction was not supported by sufficient evidence and is reversed. |
Key Cases Cited
- LeMay v. Leander, 994 P.2d 546 (2000) (orders must set forth specific, unequivocal commands before civil contempt may be imposed)
- Kam v. Noh, 770 P.2d 414 (1989) (words used in different parts of an instrument/statute are presumed to have the same meaning throughout)
- In re Taxes of Johnson, 356 P.2d 1028 (1960) (words in statutes/ orders are to be taken in their ordinary and familiar signification)
- State v. Bayly, 185 P.3d 186 (2008) (canonical rule that penal provisions/ambiguities should be construed in favor of the accused)