HRS 0852-0001 ANNOTATIONS

As enforcement of this section by the State focused on the location of the picketers and not on the picketing conduct itself, section not preempted by the National Labor Relations Act. 89 H. 27 (App.), 968 P.2d 194.

As section does not prohibit picketing or the communication of messages altogether, is specifically aimed at conduct causing an obstruction of ingress to or egress from public or private places, and individuals may continue to exercise rights guaranteed by the First Amendment and article I, §4 of the Hawaii constitution as long as they do not do so in a manner prohibited by this section, section not unconstitutional. 89 H. 27 (App.), 968 P.2d 194.

Section not unconstitutionally vague as: (1) a person of ordinary intelligence would have a reasonable opportunity to know that it is unlawful to refuse or wilfully fail to move as directed by an officer; (2) person may then choose between the lawful and unlawful conduct; and (3) section provides sufficiently explicit standards for those who apply it. 89 H. 27 (App.), 968 P.2d 194.