Justia Hawaii Supreme Court Opinion Summaries

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

Eckard Brandes, Inc. performed sewer pipeline cleaning, closed-circuit television (CCTV) inspection, and occasional repairs for public works projects in Hawai‘i. Historically, the company paid employees performing cleaning and inspection at a lower company rate, based on a 2005 letter from the Department of Labor and Industrial Relations (DLIR) stating that such work was not considered “construction” under Hawai‘i Revised Statutes (HRS) chapter 104 and thus not subject to prevailing wage requirements. Employees performing repairs were paid at the higher Laborer I or II rates. Scott Foyt, an employee, operated a Vactor truck for cleaning and occasionally assisted with inspection and repairs. He was paid the lower rate for cleaning and inspection, and the Laborer I or II rate for repairs.After Foyt filed a wage complaint, the DLIR investigated and determined that he should have been paid the higher Truck Driver prevailing wage for all work involving the Vactor truck, issuing a Notification of Violation and assessing back wages and penalties against Eckard Brandes. The company appealed, arguing it reasonably relied on the 2005 DLIR guidance. The Hearings Officer upheld the DLIR’s position, finding Foyt was misclassified and owed back wages.Eckard Brandes appealed to the Circuit Court of the First Circuit, which reversed the DLIR’s decision, holding that the company’s reliance on the 2005 letter was reasonable and that the DLIR could not retroactively apply its new interpretation. Foyt appealed, and the Intermediate Court of Appeals (ICA) affirmed the circuit court’s decision, agreeing that retroactive application was arbitrary and capricious.The Supreme Court of Hawai‘i affirmed the ICA’s judgment, holding that under the circumstances, the DLIR was estopped from penalizing Eckard Brandes for relying on its prior interpretation. The court found that equitable estoppel applied because the company reasonably relied on the agency’s affirmative representations. View "Eckard Brandes, Inc. v. Department of Labor and Industrial Relations" on Justia Law

Police officers in Kona, Hawai‘i, stopped a car for expired registration with Charles Zuffante as a passenger and his girlfriend as the driver. During the stop, officers observed a glass pipe and subsequently arrested both individuals. A search of Zuffante revealed 3.5 grams of methamphetamine, and a later search of the car uncovered an additional 130 grams of methamphetamine in various containers. The officers recorded the stop with body-worn cameras. The following day, a detective interrogated Zuffante in the Kona police station, where Zuffante signed a waiver of rights. Although the interrogation room was equipped for video recording, no recording was made due to claimed equipment failure. The detective did not take notes and later wrote a report summarizing Zuffante’s statements.Zuffante moved in limine in the Circuit Court of the Third Circuit to exclude the detective’s testimony about the unrecorded interrogation, arguing that admitting such testimony violated his constitutional rights and urging the court to adopt the recording requirement from Stephan v. State, as rejected in State v. Kekona. The circuit court denied the motion, and at trial, the detective testified that Zuffante confessed to possessing all the methamphetamine. Zuffante testified in his own defense, denying the confession. The jury convicted Zuffante of multiple drug offenses, and he was sentenced to twenty years in prison. On appeal, the Intermediate Court of Appeals (ICA) affirmed the conviction.The Supreme Court of the State of Hawai‘i reviewed the case and held that the Hawai‘i Constitution’s due process clause requires law enforcement to record all in-station custodial interrogations and, when feasible, all outside-the-station custodial interrogations. The court overruled State v. Kekona and established that failure to record, absent a showing of infeasibility, results in exclusion of the unrecorded statement. The court vacated the ICA’s judgment and the circuit court’s conviction, remanding for further proceedings. View "State v. Zuffante" on Justia Law

Three non-profit corporations, each formed by littoral homeowners in the Portlock neighborhood of East Honolulu, purchased narrow beachfront reserve lots that separated their homes from the ocean. In 2003, Hawai‘i enacted Act 73, which declared certain accreted lands—land gradually added to the shoreline by natural forces—to be public property, preventing private parties from registering or quieting title to such land. Shortly after purchasing the lots, the non-profits (the Ohanas) filed an inverse condemnation action, alleging that Act 73 resulted in an uncompensated taking of accreted land seaward of their lots, in violation of the Hawai‘i Constitution. The parties stipulated that, if a taking occurred, just compensation would be based on the fair market rental value of the accreted land.The Circuit Court of the First Circuit initially granted partial summary judgment to the Ohanas, and the Intermediate Court of Appeals (ICA) affirmed in part, holding that Act 73 effected a taking of existing accreted lands. On remand, after a bench trial with expert testimony, the circuit court found that the fair market rental value of the accreted land was zero dollars, based on credible evidence that the land’s use was highly restricted and had no market value. The court declined to award nominal damages or attorneys’ fees. The ICA affirmed, finding the circuit court’s factual determinations were supported by substantial evidence and that sovereign immunity barred attorneys’ fees.The Supreme Court of Hawai‘i affirmed the ICA’s judgment. It held that the circuit court did not err in awarding zero dollars as just compensation, nor in declining to award nominal damages, because the Ohanas suffered no compensable loss. The court further held that the just compensation clause of the Hawai‘i Constitution does not waive sovereign immunity for attorneys’ fees in inverse condemnation cases. View "Maunalua Bay Beach Ohana 28 v. State" on Justia Law

An employee with over twenty years of service at the State of Hawai‘i Department of Public Safety was discharged from her position as warden of a correctional facility following allegations of creating a hostile work environment and sexual harassment. The investigation led to multiple charges, some of which were sustained by a hearings officer, resulting in the Director’s decision to terminate her employment. The employee had no prior disciplinary record and had previously received recognition for her service.The employee appealed her discharge to the Merit Appeals Board (MAB), which held a contested case hearing. The MAB found credible evidence to sustain some, but not all, of the charges, including one for sexual harassment under a progressive discipline policy. However, the MAB found no credible evidence to support the charge brought under the employer’s zero-tolerance workplace violence policy. Considering the employee’s long, discipline-free record and the principle of progressive discipline, the MAB modified the discharge to a sixty-day suspension and ordered her reinstatement.The Department of Public Safety appealed to the Circuit Court of the First Circuit, which reversed the MAB’s decision, concluding that the MAB exceeded its statutory authority by applying progressive discipline rather than deferring to the zero-tolerance policy. The Intermediate Court of Appeals affirmed the circuit court’s judgment.The Supreme Court of the State of Hawai‘i reviewed the case and held that the MAB acted within its statutory authority under Hawai‘i law when it modified the disciplinary action from discharge to a sixty-day suspension. The Supreme Court determined that the sustained charges were not subject to the zero-tolerance policy, and the MAB’s application of progressive discipline was proper. The Supreme Court reversed the lower courts’ decisions and affirmed the MAB’s order. View "Department of Public Safety v. Forbes" on Justia Law