STATE V. CARROLL
63 Hawaii 345, 627 P.2d 776 (1981)
NATURE OF THE CASE: This was an appeal from the dismissal of an indictment for criminal
property damage.
FACTS: Carroll (D) was arrested for starting a fire at Jefferson School. The arresting
officer conducted a routine search and found a canister which was believed to be a container
of nasal spray. After being booked for attempted criminal property damage, the canister was
discovered again and found to contain mace. D was charged with possession of a noxious
substance. D was acquitted on the possession charge. D was then brought to trial on the
property damage charge. The trial court dismissed the charges because D had been prosecuted
previously for the possession charge, an offense arising from the same criminal episode. The
State (P) appealed.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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