The Hawaii Supreme Court has upheld the second-degree murder conviction of a Molokai man who confessed to beating his girlfriend to death in 2022, even as the same ruling forces every police department in the state to rewrite how officers read suspects their rights. Mariano Garces Jr., now 63, was convicted in July 2024 in the killing of 43-year-old Amie Kaholoaʻa, and the state's high court rejected his bid to have his confession thrown out.
According to Hawaii News Now, Garces was handcuffed outside his Molokai home and later taken to the police station, where two Maui Police Department detectives interrogated him. Garces admitted to killing Kaholoaʻa, telling detectives he became enraged after his prayers to bring her back to life went unanswered and that he had believed she was cheating on him. He also said he suffocated her with a shirt, beat her with a stainless steel vacuum extender, and dragged her back into the house, according to the same report.
Garces told investigators he attempted to give Kaholoaʻa CPR, that she ran outside screaming for help, and that he believed he had killed her but tried to save her anyway. He said he fell asleep before eventually calling 911 after the attack, and the outlet's report notes he became agitated and suicidal during his arrest, showing signs of distress over her death.
Why the Confession Stayed on the Record
Garces' attorney, Brandon Segal, argued at the state's highest court that his client's emotional confession should have been excluded because detectives never told him he could stop answering questions at any time. The Hawaii Supreme Court agreed that the Miranda waiver Garces signed was constitutionally deficient, ruling in its August 24 opinion, written by Associate Justice Sabrina S. McKenna, that under Article I, Section 10 of the Hawaii Constitution, officers statewide must explicitly advise custodial suspects of their right to stop answering questions and request counsel once an interrogation begins, according to CaseMine.
Despite identifying that flaw, the court ruled the new requirement applies only prospectively, taking effect 60 days after the opinion on October 23, 2026, giving police agencies time to revise their interrogation forms and training. Because Maui Police Department detectives followed constitutional standards that were valid at the time of the 2022 interrogation, per the same account, Garces' confession remained admissible and his conviction stood.
The decision partially overruled the 2004 precedent set in *State v. Wallace*, which had upheld Maui Police Department interrogations conducted using MPD Form 103 even without explicit language telling suspects they could end questioning at any time, the legal commentary site reports. Hawaii News Now has said it will report further once the Miranda-warning changes take effect Monday, October 23.
A Panel Ruling on a Vacant Seat
The bench that decided the case included Chief Justice Devens and Associate Justices McKenna, Eddins, and Ginoza, joined by assigned Circuit Judge Shirley M. Kawamura, who sat in place of a vacant fifth supreme court seat, according to the Hawaii State Judiciary.
Defense Argued for a Lesser Charge
Segal maintained that Garces never intended to kill Kaholoaʻa and pointed to his attempted CPR as evidence he tried to save her rather than end her life. On those grounds, the defense argued Garces should have been charged with manslaughter, which carries up to a 20-year sentence, rather than murder, which under Hawaii law carries a life term.
Warning Signs Predated the Fatal Attack
Court records reviewed by The Molokai Dispatch show that nine months before her death, in February 2022, Kaholoaʻa had petitioned for a temporary restraining order against Garces, alleging he choked her, punched her face, and struck her with a stick. She wrote in her court filing that she feared he would kill her; the petition was later dismissed after neither party showed up for the hearing. Kaholoaʻa had been Garces' girlfriend for about a year.
State court records detail that the fatal attack, on November 19, 2022, in Kaunakakai, began after an argument in the bathroom before a shower, during which Garces beat Kaholoaʻa for more than 15 minutes with a 20-inch metal vacuum extension pipe, causing severe internal bleeding and liver trauma, per Justia's account of the case. The Molokai Dispatch's earlier reporting also notes Garces was a convicted felon on probation since 2007 for firearm and drug charges, and at the time of the homicide he faced additional pending charges for illegal possession of firearms and ammunition.
The Cost of a Life Sentence
A Second Circuit Court jury convicted Garces of second-degree murder in July 2024 after five hours of deliberation, a verdict Hoodline covered at the time. He was formally sentenced on September 27, 2024, to life imprisonment with the possibility of parole, the maximum penalty allowed under Hawaii Revised Statutes § 707-701.5 and § 706-656 for second-degree murder; life without parole is reserved for first-degree murder or cases involving specific aggravating factors under a separate statute, according to Justia's summary of the law.
Hawaii state correctional data from 2026 indicates that housing an adult inmate in the state's facilities costs taxpayers roughly $112,000 a year, more than $300 a day, making Hawaii one of the most expensive states nationally for long-term incarceration. That statistic underscores the financial weight of a life sentence even as it delivers the punishment prosecutors sought for a killing that, by court record, had been foreshadowed months in advance.
