State v. Puck, 150 Haw. 220

Defendant Hardy Ah Puck was charged in two consolidated Maui cases (2017 and 2018) involving drug promotion and paraphernalia offenses.
After one day of jury selection and two days of trial in the 2017 matter, Ah Puck reached a plea agreement and on March 1, 2018 entered no contest pleas: Count 2 (promoting a detrimental drug, 2nd degree) in the 2017 case and an amended Count 2 (promoting a harmful drug, 4th degree) in the 2018 case.
At the change-of-plea hearing the court conducted an on-the-record colloquy, confirming age, education, English proficiency, absence of drugs or alcohol, clear mind, prior mental-health treatment (which Ah Puck said was stabilized), and that he had reviewed and signed the written Form K (change-of-plea form). Defense counsel certified he reviewed the form with Ah Puck.
Ah Puck later challenged his pleas on appeal, arguing the court failed to ensure the pleas were knowing, intelligent, and voluntary because it did not adequately address his mental-health treatment and possible confusion.
The Intermediate Court of Appeals reviewed the totality of circumstances (oral colloquy, Form K, counsel certification, and record of trial presence) and affirmed the judgment, holding the colloquy was sufficient and there was no plain error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in accepting Ah Puck's no contest pleas without ensuring they were knowing, intelligent, and voluntary	The State: colloquy, Form K, and counsel's certification show a sufficient on-the-record waiver under the totality of circumstances	Ah Puck: the court failed to follow up on his disclosed mental-health treatment and his post-judgment pro se filings show confusion, so the plea was not knowing or voluntary	Court affirmed: colloquy and written form provided an affirmative showing; no plain error and waiver was valid under totality of circumstances

State v. Krstoth, 378 P.3d 984 (Haw. 2016) (trial court must ensure pleas are knowing, intelligent, and voluntary)
State v. Solomon, 111 P.3d 12 (Haw. 2005) (record must explicitly show valid waiver of constitutional rights)
State v. Vaitogi, 585 P.2d 1259 (Haw. 1978) (trial court should make affirmative on-the-record showing of plea voluntariness)
State v. Friedman, 996 P.2d 268 (Haw. 2000) (totality of circumstances and need for more extensive colloquy when salient facts present)
State v. Martin, 463 P.3d 1022 (Haw. 2020) (colloquy sufficient under totality of circumstances despite evidence of mental illness when court questions defendant's clarity)
State v. Pedro, 488 P.3d 1235 (Haw. 2021) (signed Form K supports, but does not alone establish, plea validity)
State v. Hernandez, 431 P.3d 1274 (Haw. 2018) (plea validity requires knowing, intelligent, voluntary standard)
State v. Ernes, 465 P.3d 763 (Haw. 2020) (review waiver validity under totality of circumstances)
State v. Gomez-Lobato, 312 P.3d 897 (Haw. 2013) (consider defendant's background, experience, and conduct in waiver analysis)
State v. Han, 306 P.3d 128 (Haw. 2013) (mental illness can be a salient fact requiring expanded colloquy)