Justia Hawaii Supreme Court Opinion Summaries

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In this election contest, the Supreme Court entered judgment in favor of Defendants and against Plaintiffs as to all claims stated in the complaint, holding that Plaintiffs failed to establish a viable election challenge that would "cause a difference in the election results."The election result contested in this case was for the office of council member for the Wailuku-Waihe'e-Waikapu seat on the Maui County Council. On November 22, 2022, the final result was reported that Alice Lee received the most votes, with Nolan Ahia receiving 513 fewer votes. Plaintiffs, Ahia and thirty voters who resided within the election district, brought this complaint challenging the election result. The Supreme Court ordered that Lee received a majority of the votes cast and had been elected to the seat of the Wailuku-Waihe'e-Waikapu councilmember, holding that Plaintiffs' claims were unavailing. View "Ahia v. Lee " on Justia Law

Posted in: Election Law
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The Supreme Court vacated the judgment of the intermediate court of appeals' upholding Defendant's convictions for burglary in the first degree and other crimes, holding that the State caused an unreasonable delay in sentencing Defendant and that the unreasonable delay deprived Defendant of the opportunity for allocution.Specifically, the Supreme Court held (1) the State caused an unreasonable delay in sentencing, thus depriving Defendant of due process and a sentencing proceeding that was fundamentally fair, in violation of Haw. Const. art. 1, 5 and the Fourteenth Amendment to the federal Constitution; and (2) the State's unreasonable delay in sentencing Defendant deprived him of the opportunity to allocution, in violation of Haw. Const. art. I, 5. View "State v. Canosa" on Justia Law

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The Supreme Court held that, in petitions for adoption and permanent placement, a family court is free to consider any admissible evidence that addresses the best interests of the individual, including evidence supporting some best interests factors listed in Haw. Rev. Stat. 571-46(b).In 2018, the Department of Human Services (DHS) assumed temporary foster custody of two children under the Child Protective Act (CPA) and placement them with resource caregivers (RCGs). In 2020, Father stipulated to the termination of his parental rights. The children's aunt and uncle (Relatives) intervened in the CPA's permanent placement and adoption proceedings. DHS filed a petition on behalf of RCGs to adopt the children. Relatives responded by filing their own petition to adopt the children. The family court consolidated the dual adoption cases and found that adoption by the RCGs was in each child's best interest. The intermediate court of appeals affirmed. The Supreme Court affirmed, holding that a family court does not necessarily err when it relies on HRS 571-46(b)'s mandatory custody and visitation factors to guide a best interest determination in adoption and placement proceedings. View "In re ASK" on Justia Law

Posted in: Family Law
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The Supreme Court dismissed this election complaint asserting that the November 8, 2022 primary election ballot violated Haw. Const. art. II, 4 and Haw. Rev. Stat. 12-31 and that James Malish should have been included in the 2022 general election ballot because he was unopposed as a nonpartisan candidate, holding that Plaintiffs were not entitled to relief.Plaintiffs Karl Dicks, an unsuccessful Republican candidate for the office of State Senator, District 17, and Malish, the only nonpartisan candidate in the primary election for the office of State Senator, District 9, brought this pro se complaint asserting that the primary election ballot unconstitutionally required selection of a political preference and that the manner in which it displayed a nonpartisan candidate could be construed to require declaration of a political preference when selecting a nonpartisan ballot. The Supreme Court dismissed the complaint, holding that the election complaint failed to state a claim on which relief may be granted. View "Malish v. Nago " on Justia Law

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The Supreme Court vacated the opinion of the intermediate court of appeals (ICA) affirming the order of the circuit court granting summary judgment against Jonah Ke'eaumoku Kapu and in favor of Makila Land Co., LLC on Makila's paper title claim to real property in Maui and denying Kapu's claim for ownership of the property by adverse possession, holding that the circuit court abused its discretion.At issue before the Supreme Court was whether a letter from Kapu should have been liberally construed by the circuit court as a motion for reconsideration of the order granting summary judgment to Makila Land Co., LLC, an order that resulted in Kapu losing his home. The Supreme Court agreed with Kapu on appeal, holding (1) Kapu's pro se letter should have been liberally construed as a motion for reconsideration pursuant to the Supreme Court's policy to afford pro se litigants equal access to justice; and (2) the circuit court erred in failing to provide Kapu an opportunity to be heard on the merits of that motion. View "Makila Land Co., LLC v. Kapu" on Justia Law

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The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court denying Defendant's motion to dismiss the counts against him, holding that Defendant was not entitled to relief on his allegations of error.Defendant was indicted for leaving the scene of an accident involving death or serious bodily injury (count one) and negligent homicide in the second degree (count two). After a trial, the jury found Defendant guilty on both counts. Before sentencing, Defendant moved to dismiss count one and count two, arguing that both counts were defective. The circuit court denied the motion to dismiss, and the ICA affirmed. The Supreme Court affirmed, holding that Defendant did not show that the State's indictment violated his right to know the nature and cause of the accusations against him. View "State v. Blyenburg" on Justia Law

Posted in: Criminal Law
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The Supreme Court ruled that the intermediate court of appeals (ICA) had jurisdiction to review the merits of Appellant's postconviction appeal even though the appeal was not properly taken from a final order, holding that the appeal's procedural defects stemmed from ineffective assistance of counsel.Appellant pled no contest to murder in the second degree and was sentenced to life in prison with the possibility of parole. The ICA dismissed Appellant's appeal for lack of appellate jurisdiction because the appeal had not been taken from a final order. The Supreme Court vacated the ICA's decision, holding (1) the order appealed from was not final, and the appeal did not give rise to appellate jurisdiction; and (2) this Court presumes prejudice to Appellant from his counsel's failure to take the procedural steps necessary to make the appeal that Appellant desired, and the appropriate remedy is consideration of the appeal on its merits. View "Suitt v. State" on Justia Law

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In this petition for an extraordinary writ the Supreme Court held that when probable cause has been found after a preliminary hearing but the case is dismissed without prejudice due to a defect in the prosecution, Haw. R. Pen. P. 12(g) permits a court to hold a defendant in custody or continue bail for a specified time that is reasonable under the circumstances.After the court dismissed charges against Scott Deangelo, it ordered under Rule 12(g) that Deangelo remain in custody for ninety days while the State sought a grand jury indictment. Deangelo brought this challenge to Rule 12(g), arguing that it violates the Fourth Amendment to the United States Constitution and Haw. Rev. Stat. 803-9(5), which requires an arrested person to be taken before a qualified magistrate for examination within forty-eight hours of arrest. The Supreme Court held that Rule 12(g) is constitutional and that the time specified must be reasonable in light of all of the circumstances. View "Deangelo v. Souza" on Justia Law

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The Supreme Court reversed in part the decision of the intermediate court of appeals (ICA) affirming the decision of the district court granting Defendant's motion to suppress his answers to the medical rule-out questions given subsequent to a traffic stop, holding that the ICA erred in affirming the district court's suppression of Defendant's answers to the medical rule-out questions.In granting Defendant's motion to suppress, the district court found that Defendant was subject to custodial interrogation without being given the required warnings under Miranda v. Arizona, 384 U.S. 436 (1966). The ICA affirmed. The Supreme Court reversed, holding that, under this Court's decision in State v. Sagapolutele-Silva, 511 P.3d 782 (Haw. 2022), Defendant was not in custody when he was asked the medical rule-out questions because the circumstances of the stop had not risen to those of a formal arrest. View "State v. Tronson " on Justia Law

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In this case arising out of the Department of Human Services' attempt to recover payments made to Dr. Frederick Nitta from its Medicaid Primary Care Physician Program the Supreme Court vacated the judgment of the intermediate court of appeals (ICA) to the extent it remanded the case and otherwise affirmed, holding that DHS's claims largely lacked merit.The Program at issue was established by 42 U.S.C. 1396a(a)(13)(C) of the Affordable Care Act (ACA) and enabled certain physicians to temporarily receive increased payments for primary care services provided in 2013 and 2014 to Medicaid patients. In this case, DHS demanded repayment of more than $200,000 in enhanced payments received by Nitta through the program after it determined that Nitta was ineligible for participation in the Program because he did not meet specialty requirements as set forth in a federal administrative rule. While Nitta's appeal was pending, the Court of Appeals for the Sixth Circuit invalidated the rule and remanded the case. The ICA adopted the Sixth's Circuit's analysis. The Supreme Court largely affirmed, (1) the rule is invalid because it contravenes the statute; and (2) Nitta was entitled to enhanced payments under the statute. View "Nitta v. Department of Human Services" on Justia Law