HRS 0706-0668_0005 ANNOTATIONS

State v. Kumukau: A Case for the Application of Eighth Amendment Proportionality Analysis. 13 UH L. Rev. 577.

Sentencing court's imposition of consecutive prison terms pursuant to this section constituted an abuse of discretion, where court's sole purpose in imposing consecutive terms was to maximize the supervisory power of the Hawai`i paroling authority over defendant in an attempt to facilitate the collection of court-ordered restitution. 78 H. 127, 890 P.2d 1167.

Sentencing court did not abuse its discretion in resentencing appellant to consecutive terms of imprisonment. 79 H. 281, 901 P.2d 481.

Extraordinarily sadistic and cruel manner in which defendant committed offenses and defendant's past behavioral history required retributive, incapacitative and deterrent penal objectives of consecutive terms of imprisonment achieved under this section. 83 H. 335, 926 P.2d 1258.

Discussed: 81 H. 421 (App.), 918 P.2d 228.