State v. Maddagan

Opinion of the Court by

ACOBA, J.

We hold that the first circuit court (the court) erred in summarily denying the motion to withdraw guilty plea of Defendant Appellant Noel Quintua Maddagan (Defendant). The court’s denial rested on the ground that, in violation of Hawaii Rules of Penal Procedure (HRPP) Rule 57, no withdrawal of prior counsel and substitution of the counsel who had made the motion was filed. We conclude that, under HRPP Rule 57, the court had the discretion to allow substitution on conditions other than those expressly enumerated in the Rule and that under the circumstances,…