State v. Sprattling

Opinion of the Court by

NAKAYAMA, J.

Darrell T. Sprattling appeals from the April 14, 1999 judgment of the district court of the first circuit, the Honorable George Y. Kimura presiding, convicting him of assault in the third degree, in violation of Hawai'i Revised Statutes (HRS) § 707-712(1) (1993).1 On appeal, Sprattling argues that: (1) the oral charge failed to allege “bodily injury,” an essential element of the offense; (2) the trial court failed to obtain a valid waiver of his right to a jury trial; (3) the trial court plainly erred when it questioned witnesses during trial; and (4) there…