State v. Puaoi

MOON, Chief Justice.

Defendant-appellant Joshua Puaoi appeals from his conviction of abuse of a family and household member. On appeal, Puaoi urges reversal of his conviction on the ground that plaintiff-appellee State of Hawaii (the prosecution) failed to prove venue beyond a reasonable doubt.

Based on our conclusion that it is appropriate for this court to take judicial notice of venue, we hold that venue was proven beyond a reasonable doubt. However, we recognize as plain error the prosecution’s failure to present any evidence that Puaoi and the complaining witness were family or household…