The Hawaii Intermediate Court of Appeals has upheld the conviction of Natisha Tautalatasi for assault. The court's decision, issued on June 24, 2026, affects Tautalatasi, who was found guilty of Assault in the Second Degree after a jury trial. This ruling is significant as it confirms the legal standards for jury instructions and the handling of evidence in criminal cases.
The case began with a violent incident on September 17, 2018, at the Kona Seaside Hotel in Kailua-Kona, Hawaii. Tautalatasi, along with Wesley Samoa and another defendant, was charged with Attempted Murder in the Second Degree after security guard John Kanui suffered severe injuries during an altercation. The incident was captured on surveillance video, which later became crucial evidence in the case.
Initially, Tautalatasi and Samoa were convicted, but the Hawaii Intermediate Court of Appeals vacated their convictions due to trial errors and ordered a new trial. Following the new indictment in March 2023, the second trial commenced on January 18, 2024, resulting in Tautalatasi's conviction for Assault in the Second Degree. The trial court sentenced her on June 14, 2024, leading to her appeal.
In her appeal, Tautalatasi raised three main issues. She argued that the trial court made errors in jury instructions regarding self-defense, the order of included offense instructions, and the denial of her motion to suppress statements made to police. The court addressed each of these points in detail.
Regarding the self-defense instruction, Tautalatasi claimed that the jury was incorrectly instructed on the use of deadly force. She argued that the inclusion of the word “immediately” in the instruction was erroneous, as it was not part of the relevant Hawaii statute. However, the court found that the trial court had erred in giving her proposed instruction but determined that the error was harmless. The court noted that the evidence, particularly the surveillance video, showed Tautalatasi's actions did not support a claim of self-defense.
On the issue of jury instructions for included offenses, Tautalatasi contended that the trial court should have combined the instructions for Attempted Assault in the First Degree and Reckless Endangering in the Second Degree. The court found that the trial court acted appropriately by instructing the jury separately on the included offenses, which helped avoid confusion.
Finally, Tautalatasi challenged the denial of her motion to suppress statements made to Officer Matthew Taira and her prior testimony from the first trial. The court ruled that any potential error in denying the motion to suppress was harmless, as the statements were not introduced at trial. Additionally, the court noted that Tautalatasi had testified in her defense without the prosecution using her prior testimony against her.
The court concluded, "The June 14, 2024 Judgment of Conviction and Sentence as to Natisha Tautalatasi is affirmed." This ruling was made by Chief Judge Karen T. Nakasone, along with Associate Judges Katherine G. Leonard and Keith K. Hiraoka.
The decision has implications for future cases involving jury instructions and the admissibility of evidence in criminal trials. It reinforces the principle that errors in jury instructions can be deemed harmless if the evidence overwhelmingly contradicts the defense's claims. This ruling may affect how similar cases are handled in the future, particularly regarding the standards for self-defense claims and the presentation of evidence.
As for what’s next, Tautalatasi may seek further legal recourse, including the possibility of an appeal to the Hawaii Supreme Court. However, details about any related cases or further appeals were not available in the court filing.