Hawaii Supreme Court Allows Trial for Four HPD Officers
The state court rejected an appeal from police to dismiss charges following a 2021 crash in Makaha.
Updated on Oct. 20, 2026 in Accidents
The Hawaii Supreme Court ruled that police officers involved in a chase that results in a collision can be held criminally liable, even without physical contact. The decision clears the way for the prosecution of four Honolulu Police Department officers.
Why it matters
The ruling settles a legal debate over the definition of a collision, clarifying that officers who pursue a vehicle that subsequently crashes have a duty to stop and render aid. This legal precedent removes a major obstacle that had delayed the criminal proceedings for years.
The Hawaii Supreme Court rejected the defense appeal to dismiss charges, allowing the case against four officers to proceed. The criminal trial is set for April 2027, following a $24 million settlement across three civil lawsuits.
The players
Joshua Nahulu
He is an officer charged with accident involving serious bodily injury following the 2021 incident.
Erik Smith
He is one of the officers charged with hindering prosecution and conspiracy in relation to the crash.
Jake Bartolome
He is an officer facing charges of conspiracy and hindering prosecution.
Robert Lewis III
He is an officer charged with hindering prosecution and conspiracy.
Honolulu Police Department
This is the law enforcement agency employing the officers involved in the crash and the subsequent legal case.
The details
Officer Joshua Nahulu faces charges of accident involving serious bodily injury, while Erik Smith, Jake Bartolome, and Robert Lewis III are charged with hindering prosecution and conspiracy. The 2021 crash, which occurred after a chase on Farrington Highway, resulted in serious injuries to six people.
Timeline
A white sedan crashed in Makaha, injuring six people in September 2021.
The four officers were arrested in 2023.
The Hawaii Supreme Court rejected the defense appeal in 2026.
The criminal trial for the officers is scheduled for April 26, 2027.
Legal Context
The ruling provides a significant interpretation of Hawaii state motor vehicle collision statutes as they apply to law enforcement conduct. By rejecting the defense claim that physical contact is required to establish involvement, the court set a new standard for police accountability in the state.
The resolution of this appeal allows the criminal case to move toward trial, providing a clear path for legal accountability for the 2021 incident. Residents may see continued media and public scrutiny as the case progresses toward the 2027 court date.
The takeaway
This court decision reinforces the legal expectation that officers must prioritize rendering aid during vehicle pursuits. It underscores that legal immunity for police is not absolute when actions lead to serious harm, regardless of whether a direct collision occurs.
What happens next
The criminal trial for the four officers is scheduled to begin on April 26, 2027.
Further reading
Learn more about local investigations in the Honolulu accidents section.
Source note: This article includes information reported by Hawaiinewsnow.
