Justia Hawaii Supreme Court Opinion Summaries

by
The Supreme Court answered a certified question by concluding that, under Hawai'i law, a permissive user of an insured vehicle, whose connection to the vehicle is permission to use the vehicle to run errands and drive to work, was entitled to uninsured motorist (UM) benefits under the chain-of-events test because he was injured by an uninsured motorist.The Supreme Court determined that the proper inquiry under the chain of events test was whether a permissive user has retained a sufficient connection to the insured vehicle. The Court then held that, under the chain of events test, the driver at issue was entitled to UM benefits because he was a permissive user of the insured vehicle during the chain of events resulting in his injury caused by an uninsured motor vehicle. View "State Farm Mutual Automobile Insurance Co. v. Mizuno" on Justia Law

Posted in: Insurance Law
by
The Supreme Court ordered that this Court's August 27, 2020 order regarding temporary extension of the time requirements under Hawai'i Rules of Penal Procedure Rule 5(c)(3) for first circuit criminal matters is further extended until December 31, 2020, concluding that a further extension of the August 27 order was necessary.On August 27, 2020 the Supreme Court entered the order at issue, which provided that the first circuit may temporarily extend the time requirements for preliminary hearings no longer than reasonably necessary to protect public health and safety during the COVID-19 pandemic. Because COVID-19 cases have remained high since then, the Court extended the order until November 16, 2020. Here, the Court determined that a further extension of the August 27, 2020 order was necessary and thus extended the order until December 31, 2020. View "In re Judiciary's Response to the COVID-19 Outbreak" on Justia Law

Posted in: Health Law
by
In this divorce proceeding, the Supreme Court adopted the California Supreme Court's test for voluntariness in premarital agreements (PMA) under the Uniform Premarital Agreement Act (UPAA) and held that the family court did not err in enforcing the PMA in this case and that Wife's other asserted points of error were meritless.During the parties' divorce proceeding, Wife argued that she involuntarily executed the PMA prior to her marriage to Husband. The family court rejected Wife's argument and enforced the PMA. The Supreme Court affirmed the judgment of the intermediate court of appeals and the family court, holding that the family court did not err by (1) considering the custody evaluator's report in awarding full physical custody of the parties' minor child to Husband; (2) finding that the PMA was enforceable; and (3) failing to find that Husband abused the temporary restraining order process to gain advantage in the custody dispute. View "L.R.O. v. N.D.O." on Justia Law

Posted in: Family Law
by
The Supreme Court held that res judicata does not preclude a Haw. R. Civ. P. 60(b) motion for relief from judgment in a foreclosure proceeding and that the circuit court did not abuse its discretion in denying Appellant's Rule 60(b) motion in this case.The circuit court found Appellant in default on her mortgage and granted summary judgment in favor of Respondent. Before a foreclosure sale took place, Appellant filed a Rule 60(b) motion, challenging Respondent's standing to bring a foreclosure action against her. The circuit court denied the motion. The intermediate court of appeals affirmed, ruling that res judicata precluded Appellant's post-judgment Rule 60(b) motion. The Supreme Court affirmed on different grounds, holding (1) res judicata did not bar Appellant's Rule 60(b) motion; but (2) the circuit court properly denied the Rule 60(b) motion because there were no extraordinary circumstances warranting extraordinary relief under Rule 60(b)(6). View "Pennymac Corp. v. Godinez" on Justia Law

by
The Supreme Court extended an August 27, 2020 order for first circuit criminal matters, which was extended pursuant to a September 11, 2020 order, until November 16, 2020, determining that changing conditions wrought by the COVID-19 pandemic required flexibility and vigilance regarding the need to protect the health and safety of court users and Judiciary personnel.In July 2020, there was a surge of COVID-19 cases in Hawaii, included cases in community correctional centers and facilities, particularly at the O'ahu Community Correctional Center. As a result, the time requirements for preliminary hearings under Haw. R. Pen. P. (HRPP) 5(c)(3) was impacted. In August 2020, the Supreme Court entered an order providing that the first circuit may temporarily extend the time requirements for preliminary hearings no longer than reasonably necessary to protect public health and safety. In September, the order was extended. Because the transports of custody defendants from all O'ahu correctional facilities remained suspended and the exponential number of citations issued for Haw. Rev. Stat. ch. 127A violations remained high, the Supreme Court extended the August order for first circuit criminal matters until November 16, 2020. View "In re Judiciary’s Response to COVID-19 Outbreak" on Justia Law

by
The Supreme Court granted the Chief Election Officer's motion to dismiss Plaintiff's election complaint, holding that the Court could not grant the relief requested.Plaintiff Ashley Famera-Rosenzweig was one of four candidates in the democratic primary election for the office of U.S. Representative, District II in the August 8, 2020 primary election. Kahele received the highest number of votes in the election, and Plaintiff received the least. In her complaint, Plaintiff asked the Supreme Court to strike Kahele's name from the ballot, alleging that Kahele's voluntary assignment with the National Guard prior to the election was a tactical move to prevent all candidates from participating in appearances and debates with media networks. The Supreme Court dismissed the action, holding that Plaintiff presented no set of facts that would entitle her to the requested relief. View "Famera-Rosenzweig v. Kahele " on Justia Law

Posted in: Election Law
by
The Supreme Court dismissed Plaintiff's complaint contending that the Supreme Court should strike Kaiali'i Kahele as a democratic candidate for the office of U.S. Representative, District II, holding that Plaintiff presented no set of facts that would entitle him to the requested relief.Plaintiff Brian Evens was one of four candidates in the democratic primary election of the the office of U.S. Representative, District II in the August 8, 2020 primary election. The election results had Kahele receiving the most votes. In his complaint, Evans argued that Kahele conspired to deprive the other candidates of their right to a fair race and the public's knowledge of the candidates. The Supreme Court granted the Chief Election Officer's motion to dismiss, holding that Plaintiff failed to establish that he was entitled to relief and that Kahele's name shall be placed on the ballot as the democratic candidate in the November 2020 general election. View "Evans v. Kahele " on Justia Law

Posted in: Election Law
by
The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the district court's judgment finding Defendant guilty of resisting arrest, holding that Defendant was entitled to relief on his claim that his waiver of his right to a jury trial was not knowing, intelligent, and voluntary.Defendant signed a waiver form purporting to waive his right to a jury trial on the charge of resisting arrest. The district court accepted the waiver. After a bench trial, the court found Defendant guilty of resisting arrest and several other charges. The ICA affirmed. The Supreme Court vacated the judgments of the lower courts, holding (1) the record did not reflect a discuss and exchange sufficient to satisfy the district court's responsibility of ensuring a jury trial waiver's validity; and (2) under this Court's recent decision in State v. Ernes, 465 P.3d 763 (Haw. 2020), Defendant's waiver was not properly verified as knowing, intelligent and voluntary. View "State v. Voorhees " on Justia Law

Posted in: Criminal Law
by
The Supreme Court held that, under the totality of the circumstances in this case, the results of Defendant's breath test were admissible because Defendant validly consented to the breath test.After police arrested Defendant for habitually operating a vehicle under the influence of intoxicants an officer read Defendant the Honolulu Police Department's (HPD) implied consent form. Defendant signed and initialed the form consenting to the breath test. Defendant filed a motion to suppress the results of the breath test, arguing that his consent was not knowing, intelligent, and voluntary because the form did not comply with the implied consent statutory scheme and was, therefore, inaccurate. The circuit court suppressed Defendant's breath test results. The intermediate court of appeals (ICA) vacated the circuit court's order, concluding that suppression of Defendant's breath test was not the proper remedy for non-compliance with Haw. Rev. Stat. Chapter 291E procedures. The Supreme Court affirmed, holding (1) the implied consent form here complied with Chapter 291E and was not inaccurate or misleading; and (2) only inaccuracies in implied consent forms that are reasonably likely to influence an arrestee to consent will require suppression. View "State v. Hosaka" on Justia Law

by
In this original proceeding, the Supreme Court entered judgment dismissing this complaint asking the Court to nullify the results of the August 8, 2020 primary election for the City and County of Honolulu mayoral seat and allow all candidates who choose to continue to the November general election to have their names appear on the ballot, holding that the complaint failed to state claims upon which relief can be granted.Plaintiff was one of fifteen candidates for the City and County of Honolulu mayoral seat in the primary election. Rick Blangiardi and Keith Amemiya received the highest number of votes. Plaintiff brought this action alleging that their were multiple irregularities with the primary election. The Supreme Court dismissed the complaint, holding (1) the city clerk for the City and County of Honolulu was a necessary and indispensable party who should have been named as a defendant; and (2) in any case, the complaint failed to state claims upon which relief can be granted. View "Dicks v. State of Hawai'i Office of Elections" on Justia Law

Posted in: Election Law