State v. Bridges
925 P.2d 357, 83 Haw. 187 (1996)
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Rule of Law:
Evidence obtained in another state (the situs state) by forum state police officers is admissible in a forum state criminal prosecution if the search and seizure complied with the law of the situs state, especially when the forum officers coordinated their efforts with local law enforcement.
Facts:
- In November 1989, undercover Honolulu Police Department (HPD) officers met with California residents Fred Douglas Bridges and Timothy Lamar Bradley in California to arrange a drug transaction.
- Between December 1989 and February 1990, HPD agents made numerous telephone calls from Hawaii to Bridges and Bradley in California.
- On January 3, 1990, Bradley made a single collect telephone call from California to HPD agents in Hawaii to discuss the drug deal. Bradley never physically entered Hawaii.
- In February 1990, HPD paid for Bridges to fly to Honolulu, where he met with undercover officers to further plan the transaction and accepted a $1,000 pre-payment for cocaine.
- Bridges and the HPD agents agreed that the physical exchange of drugs would take place in California.
- On February 27, 1990, HPD, in coordination with the La Habra Police Department in California, set up a sting operation in a California hotel room.
- Without a warrant and without the consent of Bridges or Bradley, HPD agents installed audio and audio-video monitoring equipment in the hotel room after being advised by California police that a court order was not required under California law.
- In the hotel room, HPD agents gave Bridges and Bradley heroin and marijuana in exchange for cocaine, and the entire transaction was recorded by the hidden equipment.
Procedural Posture:
- Fred Douglas Bridges and Timothy Lamar Bradley were indicted in a Hawaii circuit court (trial court) on charges of Promoting a Dangerous Drug and Criminal Conspiracy.
- Prior to trial, Bradley filed a motion to suppress evidence and a motion to dismiss for lack of jurisdiction.
- Bridges subsequently joined in both of Bradley's motions.
- The circuit court granted the motions to suppress evidence for both defendants.
- The circuit court granted Bradley's motion to dismiss both counts of the indictment against him.
- The circuit court granted Bridges's motion to dismiss the promoting charge but denied his motion to dismiss the conspiracy charge.
- The State of Hawaii (prosecution) appealed the trial court's orders granting the motions to suppress and the order dismissing the conspiracy charge against Bradley to the Supreme Court of Hawaii.
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Issue:
Does evidence obtained in another state by forum state police officers, in a manner that is lawful in the situs state but would be unlawful in the forum state, need to be suppressed in a forum state criminal prosecution?
Opinions:
Majority - Klein, Justice.
No, the evidence does not need to be suppressed. The court held that because the audio/videotaping was conducted in California in compliance with California law, the evidence is admissible in a Hawaii court, even if the same conduct would have violated Hawaii law if performed in Hawaii. The court adopted an 'exclusionary rule analysis' over a traditional 'conflicts of law' approach, evaluating the three purposes of Hawaii's exclusionary rule: (1) Judicial integrity is not compromised because the evidence was obtained legally according to the laws of the situs state (California), and Hawaii's laws do not have extraterritorial effect. (2) Individual privacy interests are defined by the laws of the jurisdiction where the person is located; since the defendants' privacy was not violated under California law, this purpose is not offended. (3) The deterrence rationale is not served by suppression, as it would not deter California police who acted lawfully, and Hawaii police should be encouraged to comply with situs law by cooperating with local authorities, which they did here. There was no evidence the HPD officers acted in bad faith to evade Hawaii law.
Analysis:
This decision establishes a significant choice-of-law precedent for criminal procedure in Hawaii, clarifying how to handle evidence seized extraterritorially. By adopting an 'exclusionary rule analysis' focused on the purposes of suppression, the court created a flexible yet clear standard. It prioritizes inter-jurisdictional police cooperation and predictability for officers, mandating compliance with the law of the place of the search (the 'situs' state). This ruling provides a safe harbor for forum state police acting in another jurisdiction, so long as they act in concert with local authorities and do not consciously evade their home state's stricter constitutional requirements.
