State v. Tomas
Hawaii Intermediate Court of Appeals
1Opinion of the Court
ACOBA, Judge.
We hold in this appeal by Defendant-Appellant Nelson Tomas (Defendant) from a Hawai'i Revised Statutes (HRS) § 709-906(1) (1993) 1 conviction for abuse of his wife, Judith Tomas (Judith), a family and household member, that (1) a prior inconsistent statement is admissible as substantive evidence of the facts asserted therein and is sufficient to establish physical abuse and the manner in which it was inflicted without additional independent corroborative evidence and (2) such a statement may itself be sufficient on appeal to support a criminal conviction if it satisfies the…
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