Justia Hawaii Supreme Court Opinion Summaries

An employee, Delbert P. Costa, Jr., suffered a workplace injury on May 9, 2012, while employed by the County of Hawai'i, Department of Water Supply. Costa reported the injury, and the County filed an industrial injury claim, contesting compensability pending investigation. The County did not contest that temporary total disability (TTD) benefits would be due if the injury was compensable. The Director of the Department of Labor and Industrial Relations found the injury compensable on June 24, 2013, but the County did not appeal this decision or pay TTD benefits.Costa applied for a hearing to address the nonpayment of TTD benefits, and the Director issued a supplemental decision on April 25, 2014, awarding TTD benefits and imposing a 20% penalty for late payment. The County appealed to the Labor and Industrial Relations Appeals Board (LIRAB), which reversed the Director’s supplemental decision, finding no statutory basis for the penalty as the TTD benefits were not due before the Director’s decision on compensability.The Intermediate Court of Appeals (ICA) affirmed the LIRAB’s decision, although it noted errors in the LIRAB’s application of the evidentiary standard and its characterization of HRS § 386-92 as punitive. The ICA agreed with the LIRAB that the Director’s decision did not order TTD benefits and thus did not support the imposition of a penalty.The Supreme Court of the State of Hawai'i reviewed the case and held that a penalty under HRS § 386-92 is appropriate where an employer fails to make timely TTD benefit payments after a final decision on compensability. The Court vacated the ICA’s judgment and the LIRAB’s decision, remanding the case to the LIRAB to assess the penalty and determine attorneys’ fees and costs. View "Costa v. County of Hawai'i" on Justia Law

A landlord operated a business renting homes and had a tenant who performed repair, maintenance, and improvement work in exchange for reduced rent and payment. The tenant fell while working on the roof of one of the rental units and filed a workers' compensation claim. The landlord denied an employment relationship and disputed the work-related injury.The Director of the Department of Labor and Industrial Relations ruled in favor of the tenant, finding an employer-employee relationship. The landlord appealed, and the Labor and Industrial Relations Appeals Board (LIRAB) reversed the Director's decision, concluding there was no employment relationship under the control and relative nature of work tests. The tenant appealed to the Intermediate Court of Appeals (ICA), which vacated parts of LIRAB's decision, instructing LIRAB to apply the substantial evidence standard instead of the preponderance of the evidence standard.The Supreme Court of the State of Hawai'i reviewed the case. The court held that the landlord did not present substantial evidence to rebut the presumption of an employment relationship under the relative nature of the work test. The tenant's work was integral to the landlord's rental business, and the tenant did not have a business of his own. Therefore, the court concluded that an employer-employee relationship existed, and the tenant's injury was covered under Hawai'i's workers' compensation laws. The court vacated LIRAB's decision and the ICA's judgment, remanding the case to LIRAB to compute compensation. The court also held that the landlord was not responsible for the tenant's attorney fees and costs. View "Borrson v. Weeks" on Justia Law

The case involves Pueo Kai McGuire, who filed a 42 U.S.C. § 1983 action against the County of Hawai'i, the county prosecutor, and three deputy prosecutors, alleging violations of his constitutional rights, including malicious prosecution. The United States District Court for the District of Hawai'i certified a question to the Supreme Court of the State of Hawai'i to determine whether, under Hawai'i law, a county Prosecuting Attorney and/or Deputy Prosecuting Attorney acts on behalf of the county or the state when preparing to prosecute and/or prosecuting criminal violations of state law.The United States District Court for the District of Hawai'i reviewed the case and found the matter of whether county prosecutors act on behalf of the county or the state to be unsettled under Hawai'i law. Consequently, the court certified this question to the Supreme Court of the State of Hawai'i for clarification.The Supreme Court of the State of Hawai'i held that, under Hawai'i law, county prosecuting attorneys and their deputies act on behalf of the county when preparing to prosecute or prosecuting state law offenses. The court's decision was based on an analysis of the historical and current legal framework governing prosecutorial authority in Hawai'i, including the Hawai'i Constitution, state statutes, and county charters. The court emphasized that county prosecutors are primarily responsible for initiating and conducting criminal prosecutions within their county jurisdictions, with the state attorney general retaining only residual authority to intervene in compelling circumstances. The court declined to extend state sovereign immunity to county prosecutors, affirming that they are suable persons under 42 U.S.C. § 1983. View "McGuire v. County of Hawai'i" on Justia Law

Blossom Bell, a long-term public housing tenant, was held responsible for the criminal conduct of her guest, Daniel Lambert, who assaulted another tenant, Aaron George. Following the assault, Bell forbade Lambert from returning to her unit, and he never did. Despite this, the Oahu Eviction Board terminated Bell's rental agreement and evicted her.The Circuit Court of the First Circuit initially ruled that the Board applied the wrong legal authority and remanded the case for a new hearing. On remand, the parties agreed that the curability of Bell's violation would be governed by specific notification requirements in the rental agreement. The Board again ruled that Bell's violation was incurable and evicted her. Bell appealed, and the circuit court ruled that Bell had cured the violation by barring Lambert from the property, reversing the Board's eviction order and reinstating Bell's lease.The Supreme Court of the State of Hawai'i reviewed the case. The court held that the Board erred, abused its discretion, and acted arbitrarily and capriciously in evicting Bell. The court noted that the Board did not properly consider all relevant factors, such as the degree of crime in the housing project, the seriousness of the offending action, and the extent to which Bell took reasonable steps to mitigate the offending action. The court agreed with the circuit court that Bell's violation was curable and that she had cured it by permanently barring Lambert from the property. The Supreme Court affirmed the circuit court's final judgment reinstating Bell's lease. View "Bell v. Hawai'i Public Housing Authority" on Justia Law

In August 2023, a devastating fire in Lahaina, Maui, caused significant damage, destroying over 3,000 structures and resulting in at least 102 fatalities. Numerous lawsuits were filed by individual plaintiffs and class action plaintiffs against various defendants, including Hawaiian Electric Industries and others. Additionally, several insurance carriers filed subrogation actions to recover benefits paid to their insureds for damages caused by the fires. A global settlement agreement was reached among the plaintiffs and defendants, but the settlement required either a release of all subrogation claims by the insurance carriers or a final judgment that the insurers' exclusive remedy would be a lien against the settlement under Hawai‘i Revised Statutes (HRS) § 663-10.The Circuit Court of the Second Circuit reserved three questions for the Hawai‘i Supreme Court. The Supreme Court of the State of Hawai‘i reviewed the case and issued an opinion. The court held that the holding in Yukumoto v. Tawarahara, which limited subrogation remedies for health insurers to reimbursement from their insureds under HRS § 663-10, extends to property and casualty insurance carriers. Therefore, under HRS § 431:13-103(a)(10)(A), the lien provided for under HRS § 663-10(a) is the exclusive remedy for property and casualty insurers to recover claims paid for damages caused by a third-party tortfeasor in the context of a tort settlement.The court also held that a property and casualty insurer’s subrogation right of reimbursement is not prejudiced by its insured’s release of any tortfeasor when the settlement documents and release preserve those same rights under HRS § 663-10. Finally, the court declined to apply the made whole doctrine to the statutory lien-claim process established by HRS §§ 431:13-103(a)(10) and 663-10 under the circumstances of this mass tort case. View "In re: The Petition for the Coordination of Maui Fire Cases. S.Ct. Order" on Justia Law

Michael and Elizabeth Dailey filed an appeal with the Environmental Court of the First Circuit in July 2022, challenging a 2022 decision by the Board of Land and Natural Resources (BLNR). The decision involved a seawall allegedly constructed within the conservation district. The BLNR raised jurisdictional issues, citing Act 48 of 2016, which mandates that such appeals be filed directly with the Supreme Court of Hawaii. The Daileys argued that their case involved shoreline setback issues under HRS Chapter 205A, which would allow the environmental court to have jurisdiction.The environmental court dismissed the appeal for lack of jurisdiction, stating it did not have the authority to transfer the case to the Supreme Court. The Intermediate Court of Appeals (ICA) affirmed this decision, agreeing that the appeal arose under HRS Chapter 183C and not HRS Chapter 205A Part III, and thus should have been filed directly with the Supreme Court.The Supreme Court of Hawaii reviewed the case and determined that the Daileys' appeal did not involve the HRS Chapter 205A shoreline setback exception. Therefore, the Supreme Court had exclusive appellate jurisdiction. The court also held that the environmental court had the inherent and statutory power to transfer the appeal to the Supreme Court. The Supreme Court ordered the environmental court to transfer the appeal nunc pro tunc to the date it was originally filed, allowing the appeal to proceed in the Supreme Court under the Hawaii Rules of Appellate Procedure. View "Dailey v. Department of Land and Natural Resources" on Justia Law

A labor union, representing hotel and restaurant employees, challenged the environmental assessments (FEAs) for two condominium hotel projects developed by PACREP LLC and PACREP 2 LLC in Waikiki, Honolulu. The union argued that the FEAs were insufficient under the Hawaii Environmental Policy Act (HEPA) because they failed to discuss the potential use of condo-hotel units as permanent residences and improperly segmented the environmental review process for the two projects.The Circuit Court of the First Circuit ruled in favor of PACREP, granting summary judgment on the grounds that the FEAs were sufficient and the cases were moot because the projects were completed. The court also denied the union's motions for summary judgment, which argued that the environmental review was improperly segmented and that the FEAs were insufficient.The Supreme Court of the State of Hawaii reviewed the case and held that the union's claims were not moot because effective relief in the form of proper environmental review could still be granted. The court also determined that the public interest exception to the mootness doctrine applied. The court found that the environmental review for the two projects was improperly segmented under the double independent utility test, as the development of the second project (2139) was a necessary precedent for the first project (2121).The Supreme Court vacated the circuit court's orders granting summary judgment in favor of PACREP and the City and denying the union's motions for summary judgment. The case was remanded to the circuit court to determine whether the FEAs for the two projects were sufficient in addressing the environmental effects as one combined project and, if not, whether a new environmental assessment or environmental impact statement was required. View "Unite Here! Local 5 v. Pacrep LLC" on Justia Law

The case involves a dispute over the partition of a family-owned oceanside property in West Maui. The property, originally owned by Elizabeth Cockett Robinson, was conveyed to her children and grandchildren. After Elizabeth's passing, the property was held in undivided interests by her five children and their descendants. The property includes four residential structures, three of which are occupied by some family members, while others do not reside there. The families have attempted to subdivide or sell the property for decades without success.The Circuit Court of the Second Circuit initially ordered a partition in kind by subdividing the property into three lots, later amending it to two lots due to regulatory challenges. Eventually, the court ordered the property to be partitioned as a four-unit Condominium Property Regime (CPR), despite objections from some family members who argued that such a partition was not lawful under Hawai'i Revised Statutes (HRS) Chapter 668.The Supreme Court of the State of Hawai'i reviewed the case, focusing on whether a circuit court can order a partition by CPR under HRS Chapter 668. The court held that partition by CPR is not a lawful form of partition in kind pursuant to HRS Chapter 668. The court emphasized that the purpose of partition is to sever co-ownership ties, which a CPR does not accomplish as it creates new contractual obligations and entanglements among the owners.The Supreme Court vacated the Circuit Court's April 18, 2023 Final Judgment and related orders, remanding the case to the Circuit Court to undo the CPR, partition the property by sale, and hold further proceedings consistent with its opinion. View "Robinson v. Zarko" on Justia Law

In this case, the petitioner, a former employee, sustained a work injury in 1999 and entered into a settlement agreement in 2002, which included a lump sum payment for permanent partial disability and ongoing medical care for his left hip. In 2003, the Director of the Department of Labor and Industrial Relations (DCD) denied further treatment for the petitioner’s low back pain but allowed continued treatment for his left hip. The last payment of compensation was made in 2005.The petitioner applied to reopen his workers' compensation claim in 2017, but the Director denied the application, citing the eight-year statute of limitations under Hawai‘i Revised Statutes (HRS) § 386-89(c). The Labor and Industrial Relations Appeals Board (LIRAB) affirmed the Director’s decision, with a majority opinion stating that the petitioner had the burden of proof to show his application was timely and a concurring opinion stating that the employer had the burden of proof to show the application was untimely.The Intermediate Court of Appeals (ICA) affirmed the LIRAB’s decision, concluding that the petitioner did not provide substantial evidence to support his reopening application and that the claim was properly closed in 2007.The Supreme Court of the State of Hawai‘i held that the eight-year period in HRS § 386-89(c) is a statute of limitations, and thus, the employer has the burden of proof to show that an application for reopening a claim is untimely. The court concluded that the employer met this burden, as the last payment was made in 2005, and the petitioner’s application to reopen was filed nearly twelve years later. The court also affirmed that the workers' compensation case was properly closed in 2007. Consequently, the ICA’s Judgment on Appeal was affirmed. View "Webb v. OSF International, Inc." on Justia Law

In the 2024 general election for State Representative, District 39 in Hawaii, the two candidates were Republican Elijah Pierick and Democrat Corey Rosenlee. The election was primarily conducted by mail, with in-person voting available at voter service centers. The City Clerk of Honolulu was responsible for mailing and receiving ballots, while the State Office of Elections handled the counting. After the election, Pierick received 4,712 votes, and Rosenlee received 4,701 votes, with a vote differential of 11 in favor of Pierick. Rosenlee contested the election results, alleging mistakes in the handling of return identification envelopes and long lines at voter service centers.Rosenlee filed an election contest with the Supreme Court of Hawaii on November 25, 2024. He claimed that the Clerk made mistakes in reviewing signatures on return identification envelopes, only mailing notice of deficiencies, and managing in-person voting lines. He also alleged that the Clerk's actions violated equal protection and due process. The defendants filed motions for dismissal or summary judgment, arguing that no mistakes were made and that Rosenlee failed to provide evidence to support his claims.The Supreme Court of Hawaii reviewed the evidence and found that the Clerk followed the proper procedures for validating signatures on return identification envelopes. The court concluded that Rosenlee did not provide sufficient evidence to prove that any mistakes by the Clerk affected the election results. The court also found that the Clerk provided reasonable notice and opportunity for voters to cure deficiencies in their return identification envelopes. As a result, the court ruled in favor of the defendants and confirmed Pierick's election as State Representative, District 39. The court ordered the Chief Election Officer to deliver the certificate of election to Pierick. View "Rosenlee v. Takahashi " on Justia Law