## Facts

- Honolulu Police Department (HPD) narcotics officers, acting undercover, arranged a drug-transaction sting involving heroin, cocaine, and/or marijuana.
- The initial in-person meeting with Fred Douglas Bridges and Timothy Lamar Bradley occurred in California, where both defendants lived.
- From December 1989 to February 1990, HPD officers made multiple telephone calls from Hawaiʻi to the defendants in California to plan the transaction.
- While operating in California, HPD used audio-visual recording equipment to capture evidence related to the planned transaction.
- The recordings complied with California law and federal law but were alleged to violate a Hawaiʻi statute governing electronic interception/surveillance.
- The defendants moved to suppress the California-obtained evidence; the circuit court granted suppression, reasoning Hawaiʻi’s surveillance statute applied to HPD officers even when acting outside Hawaiʻi.
- The circuit court also dismissed the conspiracy charge against Bradley for lack of jurisdiction (and dismissed some charges as to Bridges); the State appealed the suppression orders and the conspiracy dismissal as to Bradley.

## Issues

1. Whether evidence obtained in California by Hawaiʻi police officers must be suppressed in a Hawaiʻi prosecution when the officers complied with California and federal law but allegedly violated Hawaiʻi’s electronic surveillance statute.
2. Whether Hawaiʻi courts had jurisdiction over the charged drug conspiracy as to Bradley where conduct and planning occurred across state lines but communications and contemplated effects implicated Hawaiʻi.

## Decision

- The Hawaiʻi Supreme Court reversed the suppression orders.
- The court held the recordings were admissible because the officers’ conduct in California complied with the law of the place where the evidence was obtained (California) and with federal constitutional and statutory limits.
- The court rejected applying Hawaiʻi’s electronic surveillance statute extraterritorially to require suppression for out-of-state conduct lawful where performed.
- The court reversed the order dismissing the conspiracy count against Bradley for lack of jurisdiction.
- The case was remanded for further proceedings.

## Legal Principles

- In a Hawaiʻi prosecution, evidence obtained in another state by Hawaiʻi officers is generally admissible when the collection complied with the law of the state where it occurred and with federal constitutional requirements.
- Hawaiʻi’s stricter procedural or surveillance statutes do not automatically mandate suppression for investigative acts occurring outside Hawaiʻi when those acts were lawful in the situs state.
- Hawaiʻi may exercise territorial jurisdiction over a multistate conspiracy when there are sufficient contacts connecting the agreement or its planning/communications or intended effects to Hawaiʻi.

## Conclusion

The court held that lawfully obtained out-of-state recordings by Hawaiʻi officers were admissible in Hawaiʻi and that Hawaiʻi had jurisdiction to prosecute an interstate drug conspiracy tied to Hawaiʻi through planning communications and intended in-state impact.


State v. Bridges, 925 P.2d 357 (Haw. 1996)