Lee test (Hawaii) · Go Syfert
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Lee test in Hawaii

8 Hawaii opinions name it 2 courts 1998–2025 2 in the last five years

The cases below were cited by Hawaii courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
State v. Leegreen
hawapp · 1993 · cited in 3 Hawaii opinions naming this issue, 2014–2025
2 sentences

2018App. 600 , 604, 856 P.2d 1279 , 1282 (1993) (quotation omitted). 3 See supra note 2. 4 The Lee test includes the following factors: "due diligence has been exercised to obtain the attendance of the witness, that substantial favorable evidence would be tendered by the witness, that the witness is available and willing to testify, and that the denial of the continuance would materially prejudice the defendant." 9 Haw.

2018App. 600 , 604, 856 P.2d 1279 , 1282 (1993) (quotation omitted). 3 See supra note 2. 4 The Lee test includes the following factors: "due diligence has been exercised to obtain the attendance of the witness, that substantial favorable evidence would be tendered by the witness, that the witness is available and willing to testify, and that the denial of the continuance would materially prejudice the defendant." 9 Haw.

23
State v. Williander.green
haw · 2018 · cited in 1 Hawaii opinions naming this issue, 2025–2025
2 sentences

2025See 142 Hawai‘i 155, 163, 415 P.3d 897, 905 (2018) ("We conclude that the Lee test goes too far in limiting the right to compulsory process, thus creating unnecessary burdens on defendants who wish to exercise this right.").

2025See 142 Hawai‘i 155, 163, 415 P.3d 897, 905 (2018) ("We conclude that the Lee test goes too far in limiting the right to compulsory process, thus creating unnecessary burdens on defendants who wish to exercise this right.").

11
State v. Jacksongreen
hawapp · 1991 · cited in 1 Hawaii opinions naming this issue, 2025–2025
2 sentences

2025Here, because the State was moving to continue, the Lee test still applies. 5 NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER made, not on the alternatives that might have been available." State v. Jackson, 8 Haw.

2025Here, because the State was moving to continue, the Lee test still applies. 5 NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER made, not on the alternatives that might have been available." State v. Jackson, 8 Haw.

11
Ralston v. Yim. ICA Opinion, filed 05/31/2012.green
haw · 2013 · cited in 1 Hawaii opinions naming this issue, 2024–2024
1 sentence

2024See Ralston v. Yim, 129 Hawai#i 46, 48, 292 P.3d 1276, 1278 (2013) (where the non-movant bears the burden of proof at trial, a summary judgment movant may satisfy its initial burden by "demonstrating that the non-movant will be unable to carry [its] burden of proof at trial").

11
State v. Edwardsgreen
haw · 2001 · cited in 1 Hawaii opinions naming this issue, 2020–2020
1 sentence

2020We review a trial court's ruling on a motion to suppress de novo to determine whether it was "right" or "wrong." State v. Edwards, 96 Hawai#i 224, 231, 30 P.3d 238, 245 (2001) (citation omitted).

11
State v. Williamsgreen
haw · 2007 · cited in 1 Hawaii opinions naming this issue, 2016–2016
1 sentence

2016See State v. Williams, 114 Hawaiʻi 406, 407, 163 P.3d 1143, 1144 (2007).

11
United States v. Chapelgreen
prd · 1979 · cited in 1 Hawaii opinions naming this issue, 2014–2014
2 sentences

2014All weight of authority is contrary to such wishful speculations.” Id. at 603 , 856 P.2d at 1282 (emphasis added) (quoting United States v. Chapel, 480 F.Supp. 591, 594 (D.

2014All weight of authority is contrary to such wishful speculations.” Id. at 603 , 856 P.2d at 1282 (emphasis added) (quoting United States v. Chapel, 480 F.Supp. 591, 594 (D.

11
United States v. Roy A. Walkergreen
ca5 · 1980 · cited in 1 Hawaii opinions naming this issue, 2014–2014
2 sentences

2014In moving for a continuance based on the unavailability of a witness, the movant must generally show that: “[1] due diligence has been exercised to obtain the attendance of the witness, [2] that substantial favorable evidence would be tendered by the witness, [3] that the witness is available and willing to testify, and [4] that the denial of the continuance would materially prejudice the defendant.” State v. Lee, 9 Haw.App. 600, 604 , 856 P.2d 1279, 1282 (1993) (emphasis added) (quoting United States v. Walker, 621 F.2d 163, 168 (5th Cir.1980)); see also State v. Rivera, No. 30080, 2012 WL 58

2014In moving for a continuance based on the unavailability of a witness, the movant must generally show that: “[1] due diligence has been exercised to obtain the attendance of the witness, [2] that substantial favorable evidence would be tendered by the witness, [3] that the witness is available and willing to testify, and [4] that the denial of the continuance would materially prejudice the defendant.” State v. Lee, 9 Haw.App. 600, 604 , 856 P.2d 1279, 1282 (1993) (emphasis added) (quoting United States v. Walker, 621 F.2d 163, 168 (5th Cir.1980)); see also State v. Rivera, No. 30080, 2012 WL 58

11
State v. Torresgreen
haw · 1973 · cited in 1 Hawaii opinions naming this issue, 2014–2014
2 sentences

2014This court has affirmed these concerns, stating that “[i]n deciding whether to order a continuance following a change in court-appointed counsel for an indigent defendant, the court may consider, as a factor, the need to adhere to an orderly court calendar.” State v. Torres, 54 Haw. 502, 506 , 510 P.2d 494, 497 (1973).

2014This court has affirmed these concerns, stating that “[i]n deciding whether to order a continuance following a change in court-appointed counsel for an indigent defendant, the court may consider, as a factor, the need to adhere to an orderly court calendar.” State v. Torres, 54 Haw. 502, 506 , 510 P.2d 494, 497 (1973).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Hawaii. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
United States v. Valenzuela-Bernal green
scotus · 1982
2 sentences

2018App. at 604 , 856 P.2d at 1282 . 5 The U.S. Supreme Court explained that the testimony must be beneficial to the defendant since the Sixth Amendment guarantees a defendant in a criminal case "compulsory process for obtaining witnesses in his favor ." Valenzuela-Bernal , 458 U.S. at 867 , 102 S.Ct. 3440 (quoting U.S. Const. amend.

2018App. at 604 , 856 P.2d at 1282 . 5 The U.S. Supreme Court explained that the testimony must be beneficial to the defendant since the Sixth Amendment guarantees a defendant in a criminal case "compulsory process for obtaining witnesses in his favor ." Valenzuela-Bernal , 458 U.S. at 867 , 102 S.Ct. 3440 (quoting U.S. Const. amend.

12018–2018
Robison v. Administrative Director of the Courts, State green
hawapp · 2000
2 sentences

2014All weight of authority is contrary to such wishful speculations.” Id. at 603 , 856 P.2d at 1282 (emphasis added) (quoting United States v. Chapel, 480 F.Supp. 591, 594 (D.Puerto Rico 1979)). 15 In Lee , the defendant had moved for a continuance on the day of trial, and “witnesses, summoned to appear at trial, had been waiting all morning to testify....” Id. at 604 , 856 P.2d at 1282 .

2014All weight of authority is contrary to such wishful speculations.” Id. at 603 , 856 P.2d at 1282 (emphasis added) (quoting United States v. Chapel, 480 F.Supp. 591, 594 (D.Puerto Rico 1979)). 15 In Lee , the defendant had moved for a continuance on the day of trial, and “witnesses, summoned to appear at trial, had been waiting all morning to testify....” Id. at 604 , 856 P.2d at 1282 .

12014–2014
State v. Moriwake green
haw · 1982
2 sentences

1999In Moriwake , this court addressed the prosecution’s appeal of an order granting the defendant’s motion to dismiss an indictment for manslaughter after the ease had resulted in two hung ju *210 ries. 65 Haw. at 48-50 , 647 P.2d at 708-09 .

1999In Moriwake , this court addressed the prosecution’s appeal of an order granting the defendant’s motion to dismiss an indictment for manslaughter after the ease had resulted in two hung ju *210 ries. 65 Haw. at 48-50 , 647 P.2d at 708-09 .

11999–1999
State v. Lee green
haw · 1970
2 sentences

1998Gone was the proposition, from which “we start,” “that where an individual’s conduct, or class of individuals’ conduct, does not directly harm others[,] the public interest is not affected and is not properly the subject of the police power of the legislature.” Lee, 51 Haw. at 521 , 465 P.2d at 577 .

1998Gone was the proposition, from which “we start,” “that where an individual’s conduct, or class of individuals’ conduct, does not directly harm others[,] the public interest is not affected and is not properly the subject of the police power of the legislature.” Lee, 51 Haw. at 521 , 465 P.2d at 577 .

11998–1998

Where else courts name it

CA 40 (2001–2026) TX 23 (2002–2026) IL 19 (1984–2026) GA 18 (1968–2024) WA 15 (1984–2024) FL 15 (1979–2024) NY 14 (1987–2022) IN 13 (1975–2020) PA 12 (1977–2025) AL 10 (1981–2017) MD 9 (1985–2024) VA 8 (2000–2026) HI 8 (1998–2025) OH 7 (1998–2025) DC 7 (1988–2021) AR 7 (1999–2017) MT 6 (1936–2008) LA 6 (1993–2012) NC 6 (1970–2020) UT 6 (2006–2024) MO 6 (1915–2016) NJ 5 (1978–2021) ID 5 (2015–2020) WI 5 (2009–2026) MI 4 (1918–2016) MS 4 (1987–2005) KY 4 (1949–2022) NE 4 (1987–2019) IA 3 (1992–2018) ND 3 (2012–2025) OR 3 (2002–2024) MN 3 (1992–2019) AK 3 (1988–2022) TN 2 (2007–2024) SC 2 (2019–2022) CO 2 (1973–1998) KS 2 (2011–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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