Justia Hawaii Supreme Court Opinion Summaries

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's order affirming the final decision of the Employees' Retirement System (ERS) Board and dismissing Appellant's appeal, holding that Appellant was entitled to present argument on his exceptions to the ERS Board and to have the Board consider the merits of his exceptions.The ERS denied Appellant's application for service-connected disability retirement benefits after suffering a back injury. ERS subsequently received a document filed by Appellant entitled "Petitioner's Proposed Decision." The ERS Board later issued a final decision concluding that Appellant's filing did not constitute exceptions and confirmed its denial of his application. On appeal, Appellant argued that the ERS Board's proposed decision did not automatically become a final decision because he had timely filed exceptions. The circuit court and ICA affirmed. The Supreme Court remanded this case to the ERS Board for further proceedings, holding that Appellant's "Petitioner's Proposed Decision" filing satisfied the standard for exceptions and that Appellant was entitled to present argument on his exceptions. View "Watanabe v. Employees’ Retirement System" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's denial of Defendant's second Haw. R. Penal. P. 40 petition for post-conviction relief, holding that the ICA erred in affirming the circuit court's ruling that Defendant failed to state a colorable claim that he was convicted of attempted reckless manslaughter in his second petition.Defendant's second petition arose from a 1988 conviction for two counts of attempted first degree murder, one count of attempted first degree murder, one count of attempted manslaughter, and one count of place to keep firearm. In his second Rule 40 petition, Defendant argued that his conviction of attempted manslaughter was based on reckless conduct and therefore, his sentence was illegal. The circuit court denied the petition, and the ICA affirmed. The Supreme Court vacated the ICA's judgment and Defendant's 1988 conviction for attempted manslaughter, holding (1) Defendant was convicted of attempted reckless manslaughter and was therefore subject to an illegal sentence for a non-existent crime; and (2) the presumptively harmful erroneous attempted reckless manslaughter jury instruction was not harmless beyond a reasonable doubt. View "Stanley v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that the district court rejected evidence which, if admitted, would have presented an essential factual issue for the trier of fact.After Defendant was arrested and charged with assault, one of the medical examiners, Dr. Martin Blinder, who examined Defendant opined that Defendant suffered from amphetamine psychosis and may be entitled to a lack of penal responsibility defense. The State filed a motion for a finding of inadmissibility seeking to preclude Dr. Blinder from testifying at trial. The circuit court prevented Dr. Blinder from testifying on the grounds that State v. Young, 999 P.2d 230 (Haw. 2000), had determined that a drug-induced mental illness was self-induced intoxication prohibited as a defense by Haw. Rev. Stat. 702-230(1). Defendant was convicted of assault second, and the ICA affirmed. The Supreme Court remanded the case for further proceedings, holding (1) the self-induced intoxication exception of section 702-230(1) applies only when a defendant is under the temporary influence of voluntarily ingested substances at the time of an act; and (2) by precluding Dr. Blinder's testimony at trial, the circuit court violated Defendant's due process right to present a complete defense. View "State v. Abion" on Justia Law

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In these consolidated appeals arising from Kenneth Skahan's claims for workers' compensation benefits against his former employer and its insurance carrier (collectively, Employer), the Supreme Court vacated in part the judgments of the intermediate court of appeals (ICA) affirming Labor and Industrial Relations Appeals Board's (LIRAB) decisions, holding that the ICA erred in part.Skahan injured his back while working for Employer, and Employer accepted workers' compensation liability. After Skahan's employment with Employer ended, he experienced mid and low back pain and was diagnosed with diffuse idiopathic skeletal hyperostosis (DISH) and filed multiple claims for additional workers' compensation benefits. LIRAB determined that Skahan's DISH injury was compensable because it was causally related to his work injury but that his low back injury was not compensable. The ICA affirmed. The Supreme Court vacated in part, holding (1) the ICA erred in holding that Employer rebutted the Haw. Rev. Stat. 386-85 presumption that Skahan's low back claim was for a covered work injury; (2) LIRAB's finding that Skahan's injury was permanent and stationary and at maximum medical improvement by April 19, 2013 was clearly erroneous; and (3) LIRAB's conclusion of law ending Skahan's temporary total disability benefits on April 19, 2013 was clearly erroneous. View "Skahan v. Stutts Construction Co." on Justia Law

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Due to the rate of positive COVID-19 cases and hospitalizations on O'ahu, the Supreme Court ordered that the August 27, 2020 order regarding temporary extension of the time requirements under Haw. R. Pen. P. 5(c)(3) for first circuit criminal matters is further extended until February 14, 2021.On August 27, because of a surge of COVID-19 cases in community correctional centers and facilities, especially at the O‘ahu Community Correctional Center, the Supreme Court entered its order providing that the first circuit may temporarily extend the time requirements for preliminary hearings to protect public health and safety. Because the rate of positive COVID-19 cases continues to fluctuate and the grand jury was scheduled to be in recess in January, the Supreme Court held that a further extension of the August 27 order was necessary. Thus, the Court ordered that the August 27 order be extended until February 14, 2021 unless otherwise further modified or extended. View "In re Judiciary's Response to the COVID-19 Outbreak" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals affirming Defendant's judgment of conviction and sentence for second-degree assault, holding that the circuit court erred by failing to instruct the jury on second-degree reckless endangering.At the close of trial, the circuit court instructed the jury on assault in the second and third degrees. The jury convicted Defendant of second-degree assault. In his application for writ of certiorari, Defendant argued that the circuit court was required to instruct the jury on reckless endangering in the second degree. The Supreme Court agreed, holding (1) reckless endangering in the second degree is a lesser-included offense of assault in the second degree; and (2) because there was a rational basis to acquit Defendant of assault in the second degree and to convict him of reckless endangering in the second degree, the circuit court erred when it failed to instruct the jury accordingly. View "State v. Manuel" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) in this appeal, holding that the ICA erred when it vacated the jury's civil conspiracy verdict, when it vacated an order of the circuit court on judicial admissions and judicial estoppel, and when it vacated the jury's verdict on Plaintiff's nuisance, invasion of privacy, and malicious prosecution claims.In this dispute between Plaintiff and Defendants over an easement located on Defendants' property that escalated into numerous incidents of alleged wrongful conduct by both parties, both parties appealed a $616,000 jury verdict in favor of Plaintiff. The ICA vacated the circuit court's judgment, vacated the entire jury award, and remanded the case for a new trial, holding that the circuit court made numerous errors. The Supreme Court reversed and reinstated the jury's award, holding (1) the ICA erred in vacating the circuit court's determination that Defendants judicially admitted to the existence of the easement and that its scope included vehicular ingress and egress; and (2) the ICA erred in several other respects. View "Ching v. Dung" on Justia Law

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The Supreme Court affirmed the ICA's judgment on appeal except that part of the judgment relating to an additional revocation period for having three or more prior alcohol enforcement contacts, holding that the procedures used by the Administrative Driver's License Revocation Office (the ADLRO) denied Defendant due process.The ADLRO sustained the automatic revocation of Defendant's driver's license for ten years, determining that Defendant was subject to a mandatory ten-year revocation period for operating a vehicle under the influence of an intoxicant because he had three or more prior alcohol enforcement contacts. The ICA affirmed. The Supreme Court vacated the ICA's decision in part, holding that the ADLRO erred in considering two prior alcohol enforcement contacts in determining the length of Defendant's revocation period because Defendant was unable to challenge those convictions at the revocation hearing. View "Wolcott v. Administrative Director of the Courts" on Justia Law

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In response to a question certified to it by the United States Court of Appeals for the Ninth Circuit the Supreme Court answered that the statute of limitations for a regulatory takings claim brought under the Hawai'i Constitution is six years pursuant to the catch-all statute of limitations in Haw. Rev. Stat. 657-1(4).The underlying dispute arose from the State Land Use Commission's (LUC) reclassification in 2011 of 1,060 acres of land in South Kohala on Hawai'i Island. In 2017, DW Aina Le'a Development (DW) filed this complaint alleging that the reclassification was an unconstitutional taking because the LUC failed to compensate DW for damages resulting from the land's reclassification. The federal district court dismissed the case, applying the two-year statute of limitations found in Haw. Rev. Stat. 657-7. LW appealed, arguing that the "catch-all" six-year statute of limitations applied to the action. The Ninth Circuit certified to the question to the Supreme Court. The Supreme Court held that the statute of limitations for a takings claim under the Hawai'i Constitution is six years pursuant to Haw. Rev. Code 657-1(4). View "DW Aina Le'a Development, LLC v. State Land Use Commission" on Justia Law

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The Supreme Court dismissed this election complaint challenging the result of the Office of Hawaiian Affairs (OAH) at-large trustee election in the November 3, 2020 general election, holding that Plaintiff Keoni Souza did not provide specific facts or actual information of mistakes, errors, or irregularities sufficient to change the result of the election.Souza was a candidate in the OHA at-large trustee election. Keli'i Akina received the highest number of votes, and Souza received 1,623 fewer votes than Akina. In this complaint, Souza asserted five claims for relief, alleging, among other things, that Act 135, as codified at Haw. Rev. Stat. 11-158, is arbitrary and that a recount was warranted. The Supreme Court granted Defendants' motion to dismiss, holding (1) Souza failed to demonstrate that Act 135 is arbitrary or flawed such that the results of the OHA at-large trustee election would be different; and (2) Souza was not entitled to relief on any remaining allegations of error. View "Souza v. Ige " on Justia Law

Posted in: Election Law