Speed Limit Laws In Hawaii
HRS 291C-102 provides as follows:
Noncompliance with speed limit prohibited.
(a) No person shall drive a vehicle at a speed greater than a maximum speed limit and no person shall drive a motor vehicle at a speed less than a minimum speed limit established by county ordinance.
(b) the director of transportation with respect to highways under the director's jurisdiction may place signs establishing maximum speed limits or minimum speed limits. Such signs shall be official signs and no person shall drive a vehicle at a speed greater than a maximum speed limit and no person shall drive a motor vehicle at a speed less than a minimum speed limit stated on such signs.
In State v. Lane, 57 Haw. 277, 554 P.2d 767 (1976), the defendant was convicted of violating HRS 291C-102 for operating a motor vehicle on a segment of Pali Highway at sixty-five miles per hour. a police officer testified at trial that there were speed signs along the highway which stated a thirty-mile-per-hour speed limit. In reversing the conviction, the Hawaii Supreme Court stated:
There was no evidence, and the record is devoid of information, on the question whether a maximum speed limit had been established by county ordinance or the designated stretch of Pali Highway was subject to the jurisdiction of the director of transportation and the speed signs had been placed by that officer.
The defendant moved for judgment of acquittal for failure to show that the speed signs were authorized. In denying the motion, the court stated no reasons.
the judgment of conviction adjudges only that the defendant "has been convicted of and is guilty of the violation of speeding, to wit, 65 mph in a 35 mph zone."