Justia Hawaii Supreme Court Opinion Summaries

The dispute stems from a series of lawsuits initiated by a borrower after a nonjudicial foreclosure was attempted on a Maui property he purchased in 2003. Following his default on the mortgage in 2008, the property was sold in a nonjudicial foreclosure in 2010 and title transferred to a bank. The bank, through its attorneys, sought to evict the borrower and later filed a judicial foreclosure counterclaim after the borrower challenged the foreclosure's validity. The borrower remained in possession of the property throughout, and subsequent litigation centered on the conduct of both the lender and its attorneys.After an initial summary judgment against the borrower in his wrongful foreclosure suit, the Hawai‘i Intermediate Court of Appeals (ICA) vacated and remanded for further proceedings. On remand, the parties settled most claims except those against certain attorneys. Separately, the borrower filed new claims against the bank’s law firm and its attorneys, alleging fraud, unfair and deceptive acts, wrongful foreclosure, and other torts related to their legal filings and conduct during the foreclosure process. The Circuit Court of the Second Circuit granted judgment on the pleadings in favor of the attorneys and declared the borrower a vexatious litigant due to a pattern of abusive litigation.On appeal, the ICA affirmed most of the circuit court’s rulings but reinstated the borrower’s claim alleging fraud on the court. The Supreme Court of the State of Hawai‘i held that the ICA erred by reinstating this claim, reasoning that even if the borrower’s allegations were true, they did not meet the high threshold required for an independent action for fraud on the court. The Supreme Court affirmed the circuit court’s dismissal of all claims against the attorneys and the vexatious litigant order, and vacated the ICA’s ruling to the extent it had revived the fraud on the court claim. View "Greenspon v. Deutsche Bank National Trust Company" on Justia Law

A devastating fire occurred in Lahaina on August 8, 2023, resulting in over one hundred deaths and widespread property and economic damage. Following the fire, individually represented plaintiffs and class action plaintiffs filed lawsuits in state and federal courts against entities including Hawaiian Electric, Kamehameha Schools, the State of Hawaiʻi, and the County of Maui. These class actions were eventually consolidated and refiled as a single case in the Circuit Court of the Second Circuit. Through court-ordered mediation, parties reached a “global settlement” in August 2024, resolving all claims for a total of $4.037 billion, with a portion allocated to a class settlement fund.Prior to the present appeal, the Circuit Court of the Second Circuit coordinated complex proceedings, including appointment of a special settlement master and consolidation of cases. The court issued an order establishing exclusive jurisdiction over subrogation claims related to the settlement. After the settlement was publicized and the Hawaiʻi Supreme Court issued its opinion in In re Maui Fire Cases, which clarified that insurers’ exclusive remedy after settlement is a statutory lien under HRS § 663-10, Subrogating Insurers moved to intervene in the class action, claiming protectable equitable subrogation rights if some class members did not file claims.The Supreme Court of the State of Hawaiʻi held that Subrogating Insurers do not possess a protectable interest that justifies intervention by right or permissive intervention in the class action settlement under Hawaiʻi Rules of Civil Procedure Rule 24. The court found that the statutory lien process under HRS § 663-10 is the exclusive remedy for insurers, and settlement extinguishes subrogation rights, even if some class members do not claim settlement funds. The court affirmed the Circuit Court’s order denying intervention. View "Burnes v. Hawaiian Electric Company, Inc." on Justia Law

An employee of a car rental company was involved in a motor vehicle collision while working as a transporter, driving a van on company property. The employee was at a complete stop when another vehicle reversed into the van. She reported that her nose struck the steering wheel during the collision, and subsequently experienced pain and symptoms affecting the right side of her face and nose. Medical records from the days following the accident documented her complaints of facial pain, sinus pain, and nasal congestion, and x-ray imaging taken one week after the incident revealed a nondisplaced right-sided nasal fracture. The employer accepted liability for injuries to her neck, back, and right shoulder, but denied that the nasal injury was caused by the collision.The Director of the Department of Labor and Industrial Relations found the nasal injury to be compensable under Hawaii’s workers’ compensation law. The Labor and Industrial Relations Appeals Board (LIRAB) reviewed the case and, based largely on the opinions of two medical examiners selected by the employer, reversed the Director’s decision regarding the nasal fracture. LIRAB concluded that the employer had presented substantial evidence that the nasal injury was not caused by the collision. The Intermediate Court of Appeals affirmed LIRAB’s decision, agreeing that credible medical testimony supported the employer’s position.The Supreme Court of the State of Hawaii reviewed the case and held that the employer failed to meet its initial burden of producing substantial evidence to rebut the statutory presumption that the employee’s nasal injury was work-related. The Supreme Court found that the biomechanics opinions relied on by LIRAB lacked proper foundation and did not constitute substantial evidence. The Court vacated the Intermediate Court of Appeals’ judgment and the relevant portions of LIRAB’s decision and affirmed the Director’s finding that the nasal injury was compensable, remanding for further proceedings consistent with its opinion. View "Lane v. Avis Budget Group, Inc." on Justia Law

The plaintiffs in this case are trustees who own a property in Kīhei, Maui, which they use as a vacation home for personal use. In 2021, Maui County reclassified their property as a “short-term rental” based solely on zoning, not actual use, resulting in a higher property tax rate. The plaintiffs paid the assessed taxes but did not utilize the administrative appeals process available through the Maui County Board of Review. Instead, they filed a class action in the Circuit Court of the Second Circuit, seeking a refund and alleging that the County’s collection of the higher taxes was unconstitutional, violated due process, and resulted in unjust enrichment.The Circuit Court of the Second Circuit granted the County’s motion to dismiss, finding it lacked subject matter jurisdiction. The court determined that under Hawai‘i Revised Statutes chapter 232 and Maui County Code chapter 3.48, the proper procedure for contesting real property tax assessments—including constitutional challenges—requires first appealing to the County Board of Review and, if necessary, then to the Tax Appeal Court. Because the plaintiffs bypassed these required steps and missed the statutory deadline to appeal, the court dismissed the case with prejudice.On appeal, the Supreme Court of the State of Hawai‘i affirmed the circuit court’s dismissal. The Supreme Court held that the Tax Appeal Court has exclusive jurisdiction over appeals regarding real property tax assessments, including those raising constitutional issues, and found that the plaintiffs’ claims were time-barred due to their failure to timely pursue the established administrative remedies. As a result, the Supreme Court affirmed the circuit court’s judgment dismissing the plaintiffs’ claims for lack of subject matter jurisdiction. View "Piezko v. County of Maui" on Justia Law

The defendant was convicted of second-degree murder following the disappearance of his former girlfriend, who was last seen at his apartment on January 12, 2014. The defendant claimed she left his apartment that night to be picked up by her son, but her son denied this, and she was never seen again. Evidence at trial included testimony about her abrupt disappearance, her close relationships, and her uncharacteristic lack of contact and financial activity after that date. Investigators presented circumstantial evidence, including electronic records showing her phone accessed social media from the defendant’s IP address after the time he claimed she left, and testimony about the defendant’s behavior following her disappearance.The Circuit Court of the Second Circuit initially dismissed a 2019 indictment without prejudice, but a second grand jury indicted the defendant in December 2020. The defendant moved to dismiss the second indictment, arguing insufficient evidence, juror bias, and excessive hearsay, but the circuit court denied the motion, finding probable cause. The court also denied motions to suppress the defendant’s police interview and his subscriber name obtained via subpoena, allowing only his name into evidence. At trial, the jury found the defendant guilty, and post-verdict motions for acquittal or a new trial were denied. The defendant appealed to the Intermediate Court of Appeals, raising multiple points of error, and the case was transferred to the Supreme Court of Hawaiʻi.The Supreme Court of Hawaiʻi affirmed the conviction, holding that there was sufficient evidence to support the verdict, the circuit court did not err in admitting the defendant’s statement to police or his subscriber name, and the claims of prosecutorial misconduct, plain error in jury instructions, defects in the indictment, and pre-indictment delay were not established. The court found no abuse of discretion or reversible error in the lower court’s rulings. View "State v. Brown" on Justia Law

A dispute arose over the State of Hawai‘i Board of Land and Natural Resources’ (the Board) annual continuation of a revocable water permit issued to Kaua‘i Island Utility Cooperative (KIUC) for the diversion of water from state lands to power hydropower plants. The permit, first issued in 2003, was renewed yearly through 2022. In 2019, the diversion infrastructure was severely damaged, and KIUC ceased using the water for hydropower but continued to maintain the system. Petitioners, two organizations with members asserting native Hawaiian traditional and customary rights, requested contested case hearings in 2020 and 2021, arguing that the continued diversion and disrepair of the system harmed their rights and the environment. The Board denied these requests and continued the permit.Petitioners appealed to the Circuit Court of the First Circuit (Environmental Court), challenging the denial of contested case hearings, the permit’s continuation, and alleging violations of the Board’s public trust duties. While the appeal was pending, the permit expired at the end of 2022. The Environmental Court found that Petitioners had protected property interests under the Hawai‘i Constitution, that their due process rights were violated by the denial of contested case hearings, and that the Board’s failure to issue findings of fact and conclusions of law prevented meaningful review. The court vacated and reversed the Board’s 2021 and 2022 permit continuations.The Intermediate Court of Appeals (ICA) vacated the Environmental Court’s decision, holding that Petitioners had standing under the right to a clean and healthful environment, but that the case was moot and no exceptions applied. The ICA also found no due process violation and concluded the Environmental Court exceeded its jurisdiction in reviewing the merits of the permit continuations.The Supreme Court of Hawai‘i held that exceptions to mootness applied, Petitioners had standing based on injury to traditional and customary rights, and that contested case hearings were required to protect their due process rights. The court vacated the ICA’s judgment and remanded the case to the Board for further proceedings. View "Kia'i Wai o Wai'ale'ale v. Board of Land and Natural Resources" on Justia Law

A man was charged in 2003 with second-degree murder in Hawai‘i, facing a possible life sentence without parole due to a sentencing enhancement for especially heinous crimes. After initially pleading not guilty, he changed his plea to no contest in 2004, and the court accepted the plea without the enhancement, sentencing him to life with the possibility of parole. Over the next several years, he filed four postconviction petitions, none of which challenged the validity of his plea. In 2019, the court’s records of his 2004 change of plea hearing, including recordings and stenographer notes, were disposed of according to retention policies.In 2021, after learning that no transcript of his change of plea hearing could be produced, the man filed a fifth postconviction petition under Hawai‘i Rules of Penal Procedure (HRPP) Rule 40, now represented by counsel. He argued for the first time that his plea was not made voluntarily, knowingly, and intelligently. The Circuit Court of the Third Circuit, acting as the Rule 40 Court, held an evidentiary hearing and granted relief, vacating his conviction and ordering him held without bail. The State of Hawai‘i appealed, arguing that Rule 40 was invalid, that the court lacked jurisdiction, and that the man’s claims were waived because they could have been raised earlier.The Supreme Court of the State of Hawai‘i held that Rule 40 is valid under its constitutional rulemaking authority and that the Rule 40 Court had jurisdiction. Although the man appeared to have waived his claim by not raising it in earlier petitions, the Supreme Court found that unusual circumstances and the interests of justice warranted review. On the available record, the Supreme Court concluded that the plea was constitutionally valid. The Court vacated the Rule 40 Court’s judgment and reinstated the original conviction and sentence. View "Eason v. State" on Justia Law

The dispute centers on the extension of a grading and grubbing permit issued by the Director of the Department of Public Works, County of Maui, to Maui Lani Partners for excavation work at a residential development site containing ancestral Hawaiian burial sites. In March 2018, an unincorporated association and its members challenged the validity of the permit extension, alleging violations of state and county laws requiring consultation with the State Historic Preservation Division and arguing that the Director exceeded his authority in granting the extension without good cause.The Circuit Court of the Second Circuit granted motions to dismiss the complaint on all counts without prejudice, finding no regulatory or statutory authority requiring consultation with the State Historic Preservation Division for permit extensions and that the Director acted within his discretionary authority. The court denied the plaintiffs’ motion for summary judgment and later denied their HRCP Rule 60(b)(6) motion for reconsideration, concluding that the plaintiffs had not presented new law or argument. The plaintiffs appealed to the Intermediate Court of Appeals (ICA), which affirmed the circuit court’s denial of costs and the motion for reconsideration but held that the notice of appeal was untimely because the Rule 60(b) motion was not filed within ten days of judgment and thus did not toll the appeal deadline.The Supreme Court of Hawaiʻi reviewed the case and held that a motion for reconsideration filed under HRCP Rule 60(b) is a “tolling motion” under HRAP Rule 4(a)(3) if filed within a reasonable time and before the appeal deadline, thereby extending the time to file a notice of appeal. The court also held that the ICA did not err in affirming the circuit court’s denial of the Rule 60(b)(6) motion for reconsideration. The Supreme Court vacated the ICA’s judgment in part and remanded for further proceedings. View "Kakanilua v. Director of the Department of Public Works" on Justia Law

A nonprofit organization sought access to confidential court records from child protective and adoption proceedings involving a young girl who died after being placed in foster care and later adopted. The girl was reported missing in 2021, and her death was confirmed in 2023. The records also contained information about her siblings. The siblings, through their counsel, did not object to disclosure as long as their identities were protected through redactions. The Department of Human Services and the adoptive father opposed disclosure, arguing that the records were confidential and that redactions would not sufficiently protect privacy.The Family Court of the First Circuit denied the request, reasoning that releasing redacted records would be misleading and would not serve the public interest in understanding the response of agencies and the court to child abuse and neglect. The court concluded that the records should remain sealed, citing concerns about the completeness and potential for misunderstanding of the redacted information.The Supreme Court of the State of Hawaiʻi reviewed the case and held that, under Hawaiʻi Revised Statutes §§ 587A-40 and 578-15, public access to confidential child protective and adoption records is permitted when a foster child is missing, has suffered a near fatality, been critically injured, or has died, provided that information about living siblings is redacted to protect their privacy. The court overruled prior precedent to the extent it limited disclosure to only those purposes that further the best interests of the child, clarifying that a “legitimate purpose” for disclosure can exist independently. The court ordered the release of the redacted records and provided guidance for future requests, affirming the family court’s authority to require agencies to prepare redacted versions for public access. View "Public First Law Center v. Viola" on Justia Law

The dispute centers on an option agreement for the lease of approximately 598 acres of land owned by one party and sought by another for use in a biomass power plant operation. The option agreement granted the potential lessee an irrevocable one-year option to lease the property, with a proposed lease attached that included some terms, such as base rent amounts, but omitted others, including the effective date and certain pricing details for a percentage rent provision. After the lessee attempted to exercise the option, the lessor sent a lease largely in the form of the proposed lease, but with key terms still blank. The lessee never signed this lease, and the parties disagreed about whether a binding lease had been formed.The owner filed suit in the Circuit Court of the Fifth Circuit, seeking breach of contract and specific performance. After a bench trial, the circuit court found that the proposed lease was missing essential terms and that the parties did not intend to be bound by it when executing the option agreement. The court granted the lessee’s motion for directed verdict, awarded attorneys’ fees and costs, and entered final judgment. On appeal, the Intermediate Court of Appeals (ICA) vacated the circuit court’s judgment, holding that the proposed lease was sufficiently definite and enforceable, and that the parties were bound by its terms upon exercise of the option.The Supreme Court of Hawai‘i reviewed the ICA’s decision. It held that the proposed lease lacked sufficiently definite terms, specifically regarding the effective date and percentage rent provision, and that the parties did not intend to be bound by the proposed lease without further negotiation. The Supreme Court reversed the ICA’s judgment and affirmed the circuit court’s directed verdict, fee award, and final judgment in favor of the lessee. View "Moloaa Farms LLC v. Green Energy Team LLC" on Justia Law