Hawaii Revised Statutes

Haw. Rev. Stat. § 702-201 (2026)

  "Voluntary act" defined

✓ current as of July 2026
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     §702-201  "Voluntary act" defined.  "Voluntary act" means a bodily movement performed consciously or habitually as the result of the effort or determination of the defendant. [L 1972, c 9, pt of §1]

 

COMMENTARY ON §702-201

 

  This section defines "voluntary act" in general terms relying chiefly on the characteristic of voluntariness--the effort and determination of the defendant.  The Code's formulation is intended to exclude from the category of voluntary action such bodily movements as (a) reflex or convulsions, (b) bodily movements during unconsciousness and sleep, (c) conduct during hypnosis or resulting from hypnotic suggestion, and (d) any other bodily movement that is not a product of the effort and determination of the defendant, either conscious or habitual.

  The exclusion of involuntary action from the scope of penal liability must be viewed in the light of the provisions of chapter 704 on physical disease, disorder, and defect which exclude penal responsibility.  In that chapter acquittal is conditioned on submission to treatment or commitment tailored to the condition which excludes responsibility.  The Code attempts to provide "therapy or ... custodial commitment"[1] for those dangerous individuals who are unable to conform their conduct to the requirements of the law because of some condition which would be difficult to regard as a "mental disease or defect" under orthodox treatment of penal irresponsibility.  At the same time, because treatment is flexible and tailored to the condition in question, it does not bear "harshly on the individual whose condition is nonrecurrent."[2]

  No prior Hawaii statutory provision dealt with the issue of voluntariness of acts (other than in its relation to duress or mental disease, disorder, or defect), however, a recent case tends to support the position of the Code.[3]

 

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§702-201 Commentary:

 

1.  M.P.C., Tentative Draft No. 4, comments at 119 (1955).

 

2.  Id. at 121.

 

3.  See State v. Matsuda, 50 Haw. 128, 432 P.2d 888 (1967).

 

 

Notes of Decisions
Cited in 9 cases (1 in the last 5 years), 1998–2024 · leading case: State v. Jenkins, 997 P.2d 13 (Haw. 2000).
State v. Jenkins, 997 P.2d 13 (Haw. 2000). · cites it 4× “" HRS § 702-201 defines "voluntary act" as "a bodily movement performed consciously or habitually as the result of the effort or determination of the defendant.”
State v. Moniz, 992 P.2d 741 (Haw. App. 1999). · cites it 4× “HRS § 702-201 (1993). "`Voluntary act' means a bodily movement performed consciously or habitually as the result of the effort or determination of the defendant.”
State v. Kupihea, 46 P.3d 498 (Haw. 2002). · cites it 2× “Hence, in proving the conduct element, the prosecution will have in fact presented evidence of the "voluntary act,” HRS § 702-201 (1993), which, pursuant to HRS § 702-202, "includes possession," because the "elements of an offense [include] such .”
State v. Feliciano, 115 P.3d 648 (Haw. 2005). · cites it 2× “" Hawai`i Revised Statutes (HRS) § 702-201 (1993). [7] HRS § 701-118(4) defines "conduct" as "an act or omission, or, where relevant, a series of acts or a series of omissions, or a series of acts and omissions[.”
State v. Auwae, 968 P.2d 1070 (Haw. App. 1998). · cites it 2× “” HRS § 702-201 (1993). With respect to possession, HRS § 702-202 states that “possession is a voluntary act if the defendant knowingly procured or received the thing possessed or if the defendant was aware of the defendant’s control of it for a sufficient period to have been…”
State v. Pond, 181 P.3d 415 (Haw. App. 2007). · cites it 2× “The supreme court determined, however, that the circuit court’s erroneous response to a jury communication 12 “adversely affected Aganon’s substantial rights and, as such, constituted plain error[,]” warranting vacatur of Aganon’s conviction and sentence and a remand for a new…”
State v. Foster., 282 P.3d 560 (Haw. 2012). · cites it 2× “HRS § 702-201 (1993). A “ ‘[voluntary act’ means a bodily movement performed consciously or habitually as the result of the effort or determination of the defendant.”
State v. Keawemauhili, 157 P.3d 539 (Haw. App. 2007). · cites it 2× “Whether the District Court Erred in Applying HRS § 702-201 to Supply the “Intentional, Knowing, or Reckless” State of Mind for the Elements of the Camping-Without-ar-Permit Offense During the proceedings below, Appellants argued that Camping Rule § 3(5), by ex *106 pressly…”
State v. Cardona. ICA s.d.o., filed 02/06/2024 [ada], 153 Haw. 579. Application for Writ of Certiorari, filed 03/25/2024. S.Ct. Order Accepting Application for Writ of Certiorari, filed 05/07/2024 [ada]., 556 P.3d 369 (Haw. 2024). · cites it 2× “”); HRS § 702-201 (“‘A voluntary act’ means a bodily movement performed consciously or habitually as the result of the effort or determination of the defendant.”
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