Ciacci v. Woolley

Minor John Doe (Minor) appeals from the order of the Family Court of the First Circuit, adjudicating him a law violator under Hawaii Revised Statutes (HRS) § 571-11(1), based on its ruling that he was in possession of a "butterfly" knife in violation of HRS § 134-52. Minor raises two points on appeal: 1) whether a butterfly knife is prohibited as a type of switchblade knife under HRS § 134-52; and 2) whether HRS § 134-52 is unconstitutionally vague as applied to butterfly knives. Based on the language and legislative history of § 134-52, we conclude that a butterfly knife is not a switchblade knife, and therefore reverse the order of the family court. Consequently, we do not reach Minors second contention of error.