LAW.coLAW.co

State v. Akau

2026-08-28

Summary

Holding. The appellate court vacated the conviction and remanded for a new trial, finding that the trial court's failure to define theft and its associated mental-state requirement when instructing the jury on Robbery in the Second Degree constituted erroneous and presumptively harmful error that was not harmless beyond a reasonable doubt.

Michael Akau was convicted of Robbery in the Second Degree following a jury trial. The evidence showed that Akau and Steven Andrews fought over Andrews's belongings at a 7-Eleven; Andrews testified that Akau initially grabbed his Walmart bag, which Andrews then recovered during their struggle. After the altercation, some of Andrews's items were missing. Akau testified he did not take the bag and only asked for a cigarette before being punched by Andrews.

The Intermediate Court of Appeals identified a critical error in the jury instructions. The trial court explained Robbery in the Second Degree as using force while "in the course of committing theft," but failed to provide the jury with the statutory definition of theft, which requires proof that the defendant acted with intent to deprive the victim of property. Although the court later defined theft when instructing on a lesser-included offense, the appellate court found this insufficient to cure the error. The court concluded that without the theft definition tied to the robbery charge, a jury could have convicted Akau based solely on his fight causing Andrews to abandon his property, without finding that Akau intended to deprive Andrews of it.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether jury instructions on robbery must include the statutory definition of theft and its mens rea element
  • Whether providing a theft definition only in a lesser-included offense instruction cures the omission from the primary charge
  • Whether erroneous jury instructions were harmless beyond a reasonable doubt

Procedural posture

Akau appealed his conviction for Robbery in the Second Degree from the Circuit Court of the First Circuit, challenging the jury instructions, prosecutorial statements, and the court's handling of a restitution hearing.

Authorities cited

Opinion

majority opinion

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

Electronically Filed

Intermediate Court of Appeals

CAAP-XX-XXXXXXX

28-AUG-2026

07:51 AM

Dkt. 76 SO

NO. CAAP-XX-XXXXXXX

IN THE INTERMEDIATE COURT OF APPEALS

OF THE STATE OF HAWAI‘I

STATE OF HAWAI‘I, Plaintiff-Appellee,

v.

MICHAEL AKAU, also known as

MICHAEL JACOB AKAU, Defendant-Appellant.

APPEAL FROM THE CIRCUIT COURT OF THE FIRST CIRCUIT

(CASE NO. 1CPC-XX-XXXXXXX)

SUMMARY DISPOSITION ORDER

(By: Nakasone, Chief Judge, Leonard and Gluck, JJ.)

Defendant-Appellant Michael Akau, also known as

Michael Jacob Akau (Akau), appeals from the Circuit Court of the

First Circuit's (Circuit Court) 1 December 12, 2023 "Judgment of

Conviction and Sentence" (Judgment), in which Akau was found

guilty of Robbery in the Second Degree following a jury trial. 2

On appeal, Akau challenges the Circuit Court's jury

instructions, alleges prosecutorial misconduct, and contends

1 The Honorable James S. Kawashima presided.

2 The Circuit Court entered a "Free Standing Order of Restitution" on January 21, 2025, and Akau filed a timely notice of appeal thereafter.

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

that the Circuit Court erred by waiving his presence at a

restitution hearing.

Upon careful review of the record on appeal and the

briefs submitted, and having given due consideration to the

arguments advanced and the issues raised, we vacate and remand

due to erroneous jury instructions.

The relevant background facts are these. A jury trial

was held on August 24-25, 2023. Steven Andrews (Andrews)

testified that on November 23, 2022, he was sitting outside of

7-Eleven with a blue Walmart bag that contained a library book,

cigarettes, and some change, when Akau walked by, bent over, and

"grabbed [his] things." Andrews "grabbed the bag back," Akau

gripped the bag tighter, and the two struggled for around 30

seconds. Andrews attempted to hit Akau to make him let go of

the bag, at which point the two began fighting. Andrews

testified that he then punched Akau in the face, after which

Akau punched Andrews twice and kneed him in the back. Andrews

left the scene to return to his residence at Weinberg Hale, and

observed Akau with the bag in his (Akau's) hand. Andrews later

received his belongings back from responding officers, but

testified that "a little bit of money [was] missing" and he

could not recall if he got the cigarettes back.

Honolulu Police Department (HPD) Officer Daniel Wolf

(Officer Wolf) testified that on November 23, 2022, he was

dispatched to an "assault or a robbery type case" at Weinberg

2

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

Hale. Andrews reported to Officer Wolf that his property was

taken at 7-Eleven down the road. Officer Wolf found Andrews's

Walmart bag "tucked away into a corner" at the 7-Eleven.

Officer Wolf reviewed the surveillance footage from 7-Eleven,

but testified that he could not determine whether Akau took

Andrews's belongings. 3

Akau testified that on November 23, 2022, he was

"panhandling" at 7-Eleven. Akau saw Andrews, whom he seen

previously at Weinberg Hale and 7-Eleven, and he asked Andrews

for a cigarette. Akau testified that Andrews then punched him

in the mouth, and they began fighting. When the fighting

stopped, Andrews left, and Akau sat in the corner where Andrews

was initially sitting. Akau observed a blue tote bag "off in

the corner[,]" but denied grabbing the bag from Andrews at any

point while fighting and denied taking any items from the bag.

Akau testified that his friend then came over and gave him a

cigarette.

The Circuit Court instructed the jury on Robbery in

the Second Degree, use of force, as follows:

Robbery in the Second Degree, use of force. As to

the first alternative, a person commits the offense of

Robbery in the Second Degree, use of force, if in the

course of committing theft he uses force against the person

of anyone present with the -- with intent to overcome the

person's physical resistance, or physical power of

resistance.

There are two material elements to the offense of

Robbery in the Second Degree, use of force, each of which

3 Although the surveillance video is listed in the record on appeal, the video itself was not available for this court to review.

3

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

the prosecution must prove beyond a reasonable doubt. The

two elements are:

1. That on or about November 23rd, 2022, in the City

and County of Honolulu, state -- the defendant, Michael

Akau, was in the course of committing theft; and

2. That while doing so the defendant, Michael Akau,

used force against the person of Steven Kermit Andrews, a

person who was present, with intent to overcome Steven

Kermit Andrews's physical resistance or physical power of

resistance.

(Emphases added.) The Circuit Court did not provide the jury

with the statutory definition of "theft" (from Hawaiʻi Revised

Statutes (HRS) § 708-830) when instructing the jury on Robbery

in the Second Degree. 4

4 The Circuit Court did, however, define the following terms:

Control over the property means exercise of the --the exercise of dominion over the property, and includes

but is not limited to taking, carrying away, or possessing

the property, or selling, conveying, or transferring title

to or an interest in the property.

Deprive means A, to withhold property or cause it to

be withheld from a person permanently, or for so extended a

period, or under such circumstance, that a significant

portion of its economic value or the use -- or the use and

benefit thereof is lost to him; or

B, to dispose of the property, so as to make it

unlikely the owner will recover it; or

C, to retain the property with the intent to restore

it to the owner only if the owner purchases or leases it

back, or pays a reward or other compensation for its

return; or

D, to sell, give, pledge or otherwise transfer any

interest in the property; or

E, to subject the property to a claim of a person

other than the owner.

Obtain means, when used in relation to property, to

bring about a transfer of possession or other interest,

whether to the obtainer or to another.

Unauthorized control over property means control over

property of another which is not authorized by the owner.

4

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

Thereafter, the Circuit Court instructed the jury that if it

found Akau not guilty of Robbery in the Second Degree, it would

determine whether Akau was guilty of Theft in the Fourth Degree,

as follows:

A person commits the offense of Theft in the Fourth

Degree if he obtains or exerts unauthorized control over

the property of another, the value of which does not exceed

250 dollars, with intent to deprive the person of the

property.

There are four material elements of the

offense of Theft in the Fourth Degree, each of which the

prosecution must prove beyond a reasonable doubt.

These four elements are:

1. That on or about November 23rd, 2022, in the City

and County of Honolulu, the State of Hawaiʻi, the defendant,

Michael Akau, obtained or exerted unauthorized control over

the property of Steven Kermit Andrews; and

2. That the defendant, Michael Akau, did so with the

intent to deprive Steven Kermit Andrews of the property;

and

3. That the defendant, Michael Akau, was aware or

believed the property had value; and

4. The property had value.

In closing argument, the State reiterated the

"depriving" definition, as follows:

You've learned about what depriving is. Depriving is

to withhold the property, permanently or for so extended a

period that a significant portion of it, or its value, is

lost. You've also learned that deprived can mean to

dispose of it, to make it unlikely that the person, Mr.

Andrews, could recover it.

You've learned that it means to retain the property,

with the intent to restore it only if the owner purchases

it or leases it back. Depriving also means to sell or

otherwise transfer the interest of the property to someone

else. It's not yours. To subject the property to the

claim of a person other than the owner, in this case Mr.

Andrews.

The State argued that Akau approached Andrews with the goal "to

take whatever it was that Mr. Andrews had[,]" and that Akau then

5

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

punched and kneed Andrews in the back causing Andrews to flee

the 7-Eleven parking lot and leave his belongings behind. The

State argued that Andrews observed Akau with the "blue tote in

his hand" while fleeing. After Andrews left, the State

contended, the surveillance video showed Akau smoking a

cigarette, which was from Andrews's bag.

In its rebuttal argument to the jury, the State argued

that "[i]t didn't have to be the defendant who took anything

from the wallet, or took any cigarettes from the bag, under the

law." The State contended that because of Akau's actions,

"Andrews was forced to abandon his belongings," and it did not

matter "if the defendant took the cigarettes, or the book, . . .

or the cash[.]" Defense counsel objected for "misstate[ment of]

the law." The Circuit Court overruled the objection.

The jury found Akau guilty as charged of Robbery in the

Second Degree, use of force. Akau was sentenced to ten years of

imprisonment. Akau timely appealed.

Standard of review.

When jury instructions or the omission thereof are at

issue on appeal, the standard of review is whether, when

read and considered as a whole, the instructions given are

prejudicially insufficient, erroneous, inconsistent, or

misleading. Erroneous instructions are presumptively

harmful and are a ground for reversal unless it

affirmatively appears from the record as a whole that the

error was not prejudicial. However, error is not to be

viewed in isolation and considered purely in the abstract.

It must be examined in the light of the entire proceedings

and given the effect which the whole record shows it to be

entitled. In that context, the real question becomes

whether there is a reasonable possibility that error might

have contributed to conviction. If there is such a

reasonable possibility in a criminal case, then the error

is not harmless beyond a reasonable doubt, and the judgment of

conviction on which it may have been based must be set aside.

6

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

State v. Nichols, 111 Hawaiʻi 327, 334, 141 P.3d 974, 981 (2006)

(quoting State v. Gonsalves, 108 Hawai‘i 289, 292–93, 119 P.3d

597, 600–01 (2005)) (brackets omitted). "Jury instructions to

which no objection was made at trial will be reviewed for plain

error." State v. Brown, 157 Hawaiʻi 354, 367, 577 P.3d 1045,

1058 (2025).

Akau argues that the Circuit Court erred by

"failing to define theft under HRS § 708-830(1)" as including

the “mens rea for element 1 of Robbery.” Akau contends that

“[w]ithout being informed that element 1 requires an intent to

deprive another of property, a mens rea, the jury could have

believed that the State was not required to prove a mens rea at

all for that first element.” The State, on the other hand,

argues that because the Circuit Court “gave an instruction on

Theft in the Fourth Degree as a lesser included offense of

Robbery in the Second Degree[,]” “the jury was in fact provided

with a definition of ‘theft’ and the mental state associated

with ‘theft.’”

HRS § 701-114 (2014), entitled "Proof beyond a

reasonable doubt," provides:

(1) Except as otherwise provided in section 701-115,

no person may be convicted of an offense unless the

following are proved beyond a reasonable doubt:

(a) Each element of the offense;

(b) The state of mind required to establish each

element of the offense;

7

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

(2) In the absence of the proof required by

subsection (1), the innocence of the defendant is presumed.

(Emphasis added.) HRS § 702-204 (2014), entitled "State of mind

required," provides: "Except as provided in section 702-212, a

person is not guilty of an offense unless the person acted

intentionally, knowingly, recklessly, or negligently, as the law

specifies, with respect to each element of the offense."

(Emphasis added.)

Akau was found guilty of HRS § 708-841(1)(a) (2014),

which provides that a person commits Robbery in the Second

Degree if:

in the course of committing theft . . . :

(a) The person uses force against the person of

anyone present with the intent to overcome that

person's physical resistance or physical power of

resistance;

(Emphasis added.) HRS § 708-830 (2014) provides, inter alia,

that a person commits theft if the person "obtains or exerts

unauthorized control over the property of another with intent to

deprive the other of the property." (Emphasis added.) Thus, to

find Akau guilty of Robbery in the Second Degree, the jury was

required to find that, in addition to force, Akau acted "with

intent" to "deprive" Andrews of his property. See id.; HRS §§

701-114 and 702-204; see also State v. Cordeiro, 99 Hawaiʻi 390,

407, 56 P.3d 692, 709 (2002) (noting that the Circuit Court

instructed the jury on the "statutory definition[]" of "theft"

in a Robbery in the First Degree case).

8

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

Here, the Circuit Court instructed the jury as to

Robbery in the Second Degree without providing the definition of

"theft." The Circuit Court then provided the definitions of

"Control over the property," "Deprive," "Obtain," and

"Unauthorized control over property," all terms derived from the

statutory definition of "theft." As Akau argues, without the

"theft" definition, the jury could have been misled "that if

Akau somehow caused the property to be withheld from the owner

without any intent to do so, . . . then he could still be guilty

of robbery." Without the proper instruction of "theft," a jury

could have found that Akau's fight with Andrews caused Andrews

to abandon his property. Therefore, it is unclear whether the

jury understood that Akau had to have the "intent to deprive"

Andrews of his property during the fight. HRS § 708-830. Thus,

the Circuit Court's jury instructions were erroneous. See

Nichols, 111 Hawai‘i at 334, 141 P.3d at 981.

The Circuit Court's erroneous jury instructions were

presumptively harmful. Id. Based on the record, there is a

reasonable possibility that the erroneous instruction

contributed to Akau's conviction, and this error was not

harmless beyond a reasonable doubt. Accordingly, we vacate and

remand, and we need not address Akau's remaining arguments.

For the foregoing reasons, we vacate the Circuit Court

of the First Circuit's December 12, 2023 "Judgment of Conviction

9

NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER

and Sentence," and remand for proceedings consistent with this

Summary Disposition Order.

DATED: Honolulu, Hawai‘i, August 28, 2026.

On the briefs:

Audrey Stanley, /s/ Karen T. Nakasone for Defendant-Appellant. Chief Judge

Robert T. Nakatsuji, /s/ Katherine G. Leonard Deputy Prosecuting Attorney, Associate Judge

City and County of Honolulu

for Plaintiff-Appellee. /s/ Daniel M. Gluck

Associate Judge

10