Justia Hawaii Supreme Court Opinion Summaries

In this case, the defendants executed a promissory note and mortgage in 2008, which were eventually assigned to Wells Fargo Bank, N.A. In 2015, Wells Fargo initiated a foreclosure action against the defendants, alleging default on the mortgage. During the pendency of the proceedings, Wells Fargo assigned the mortgage to UMB Bank, National Association, which was substituted as the plaintiff. A central issue in the case was whether Wells Fargo possessed the original promissory note at the time the foreclosure complaint was filed, a requirement for standing to foreclose.The Circuit Court of the First Circuit first denied Wells Fargo’s summary judgment motion, finding insufficient admissible evidence of note possession at the time the lawsuit commenced. Later, UMB as successor plaintiff submitted additional declarations and business records in support of a renewed summary judgment motion. The circuit court found these sufficient and ruled in favor of UMB on standing. Shortly before trial, the parties entered into a stipulation regarding certain facts, including that Wells Fargo held the note before the action began and was the current holder, but the stipulation did not specify continuous possession or possession specifically on the complaint’s filing date. The circuit court relied on both the earlier summary judgment ruling and the stipulation, ultimately issuing a foreclosure decree for UMB. On appeal, the Intermediate Court of Appeals affirmed, emphasizing enforcement of the stipulation.The Supreme Court of the State of Hawaiʻi reviewed the case and held that there remained a genuine issue of material fact as to whether Wells Fargo possessed the note when the complaint was filed. The court found the evidence submitted by UMB ambiguous and the stipulation insufficiently specific to establish standing. The Supreme Court vacated the judgments of the lower courts and remanded the case for further proceedings to resolve this factual issue. View "UMB Bank, N.A. v. Tupulua" on Justia Law

The case concerns a defendant who was convicted of murdering his girlfriend after a violent altercation in their home. The defendant called 911, expressing both an apparent confession and suicidal intent. He was apprehended after returning home the next day. At the police station, he was advised of his rights using the Maui Police Department’s Miranda waiver form, which, at the time, did not include an explicit warning that he could stop answering questions or request an attorney at any time during interrogation. The defendant subsequently confessed during a custodial interview and did not attempt to invoke his right to silence or counsel.Proceedings in the Circuit Court of the Second Circuit were delayed to evaluate the defendant’s mental fitness. After finding him fit, the court denied his motion to suppress statements, concluding he had voluntarily, knowingly, and intelligently waived his Miranda rights, despite his claims of mental distress and the absence of the so-called “fifth Miranda warning.” At trial, the jury found him guilty of second-degree murder, and he was sentenced to life imprisonment with the possibility of parole. On appeal, the Intermediate Court of Appeals affirmed the conviction, holding that the Miranda warnings given were constitutionally sufficient and the waiver voluntary.The Supreme Court of the State of Hawai‘i reviewed the case. It held that, under the Hawai‘i Constitution, law enforcement must henceforth provide not only the traditional four Miranda warnings but also explicitly inform custodial suspects of their right to cease answering questions and request an attorney at any time. However, because this is a new constitutional rule, the court applied it prospectively only, not to the defendant’s case. The court affirmed both the conviction and sentence, holding that the defendant’s waiver was valid under the previous standard. View "State v. Garces" on Justia Law

The petitioner challenged the renewal of an annual permit granted to a hotel operator for the use of state-owned, ceded lands fronting the Kahala Hotel. The permit, which allowed the hotel to use the land for recreational and maintenance purposes, was extended several times by the Board of Land and Natural Resources (BLNR). The petitioner requested a contested case hearing (CCH) during a public meeting about the most recent renewal, arguing that the practice of pre-setting lounge chairs on the land discouraged public use. The BLNR denied the request for a hearing and approved the permit renewal. The petitioner appealed this denial.The Circuit Court of the First Circuit affirmed the BLNR’s actions, rejecting the petitioner’s arguments. The petitioner then appealed to the Intermediate Court of Appeals (ICA), which found that the petitioner had a constitutionally protected property interest in a clean and healthful environment under the Hawai‘i Constitution. The ICA concluded that the petitioner was entitled to a CCH and that the denial of such a hearing violated procedural due process. However, since the permit had expired, the ICA remanded the case to the circuit court to determine what relief could be granted, and denied the petitioner’s request for attorney fees under the private attorney general (PAG) doctrine, finding that the requirements for the doctrine had not yet been satisfied.Upon certiorari, the Supreme Court of the State of Hawai‘i held that the PAG doctrine does not require a party to obtain further relief before recovering attorney fees, and that all requirements for the doctrine were met. The court ruled that the hotel operator is liable for all reasonable attorney fees incurred by the petitioner during the certiorari proceedings, including fees for seeking fees, and remanded to the ICA to determine the amount of reasonable fees for the appellate stage. View "Ralston v. Board of Land and Natural Resources." on Justia Law

Ramona Ricapor-Hall began smoking at age twelve and continued for sixty-six years, relying on assurances from cigarette manufacturers that downplayed the dangers of smoking. Despite repeated efforts to quit, her addiction persisted. In 2019, she was diagnosed with lung cancer and later developed a second primary lung cancer. In 2021, she filed suit against cigarette manufacturers and vendors for her lung cancer, ultimately settling with all defendants except Philip Morris USA Inc.The case was tried before the Circuit Court of the First Circuit in Hawaii. The jury found Philip Morris liable for negligence, strict products liability, and intentional torts related to conspiracy to commit fraudulent concealment and misrepresentation, awarding Ricapor-Hall $6 million in general damages and $8 million in punitive damages. The jury attributed 54% fault to Philip Morris and 46% to Ricapor-Hall. The circuit court reduced her general damages by her share of fault, citing comparative negligence, and entered final judgment totaling $11,095,000 after settlement credits.On appeal to the Supreme Court of the State of Hawaii, Philip Morris challenged the verdict on several grounds, including juror substitutions, juror bias inquiry, jury instructions, and the availability of punitive damages. Ricapor-Hall cross-appealed, arguing that her negligence should not reduce damages for intentional torts. The Supreme Court held that comparative negligence does not reduce damages for intentional torts, vacated the portion of the judgment reducing Ricapor-Hall’s award, and remanded for entry of an amended judgment for the full $6 million in general damages. All other aspects of the circuit court’s judgment were affirmed. View "Ricapor-Hall v. Philip Morris USA Inc." on Justia Law

After a motor vehicle accident, an injured person received neck and shoulder treatment from a naturopathic and holistic medicine provider, specifically low level laser therapy (LLLT). The provider billed the patient’s no-fault automobile insurer for the treatment, but the insurer reimbursed only a minimal amount, recoding the claims as a different therapy and contending that LLLT was not a covered benefit. The provider asserted that state law required the insurer to fully reimburse the treatment as a personal injury protection (PIP) benefit.Following the insurer’s denial, the provider sought review through the Office of Administrative Hearings. The hearings officer initially dismissed the claim, finding insufficient evidence that LLLT was a covered PIP benefit, and the Insurance Commissioner adopted this decision. On appeal, the Circuit Court of the Third Circuit reversed, holding that dismissal without a hearing was improper, and remanded for a merits hearing. At the subsequent hearing, the provider presented evidence regarding the effectiveness of LLLT but did not establish that prepaid health care plans in Hawai‘i covered this therapy. The hearings officer again ruled for the insurer, finding the provider failed to prove the treatment was “substantially comparable” to those covered by prepaid health care plans, and the Commissioner adopted this decision. The circuit court affirmed, as did the Intermediate Court of Appeals, though the appellate court reasoned that the statute’s language required clarification by reference to a statutory definition.The Supreme Court of the State of Hawai‘i reviewed the case. It held that the statute was unambiguous and imposed two conditions for PIP coverage: the treatment must be appropriate, reasonable, and necessary, and it must be substantially comparable to the requirements for prepaid health care plans. The provider failed to satisfy the second condition. The Supreme Court affirmed the lower courts’ decisions. View "In re Request for Payment of Lawinski, v. Saiki" on Justia Law

After a couple ended their relationship, they continued to share custody of a dog they had jointly acquired. This shared arrangement lasted for two years, but in early 2026, one party refused to return the dog as scheduled. The other party then filed a claim in the small claims division of the District Court of the Second Circuit in Hawai‘i, seeking the return of the dog or, alternatively, monetary compensation. The claimant argued she co-owned the dog, had paid for its care, and that money damages would be inadequate. The defendant asserted he assumed full custody after learning the claimant might leave the island and asked the court to confirm his ownership.The District Court of the Second Circuit’s small claims division conducted a trial and found it equitable to grant legal and physical ownership of the dog to the defendant. The court also ordered the defendant to pay the claimant a sum representing half the value of the dog plus half the veterinary bills. The claimant’s motions to set aside the judgment and for reconsideration or new trial were denied, with the court reasoning that she had chosen the forum and was requesting monetary relief.The Supreme Court of the State of Hawai‘i reviewed the case on a petition for a writ of mandamus, as no appeal is allowed from a small claims judgment. The Supreme Court held that the small claims division lacked subject matter jurisdiction to decide ownership of the dog because its statutory authority is limited to money claims under $5,000, residential security-deposit disputes, and the return of leased or rented property. The claim for ownership of the dog was not within those categories. The Supreme Court granted the writ, vacated the lower court’s ruling, and remanded with instructions to dismiss the case without prejudice. View "Miller v. Collins" on Justia Law

A nonprofit environmental organization challenged the Maui Planning Commission’s amended rules, which governed development in Maui’s Special Management Area (SMA), a protected coastal zone. The amendments created fifteen categorical exemptions from environmental assessment, some with monetary thresholds and some based on landowner declarations. The rules also allowed continuation, repair, or renovation of previously approved developments without new environmental review, and replaced the requirement for a final environmental assessment (EA) with a draft EA for permit applications.After the rules were enacted, the nonprofit filed a complaint in the Circuit Court of the Second Circuit, arguing that the commission’s rules unlawfully bypassed the Coastal Zone Management Act’s (CZMA) required assessment process, shifting the duty to regulated parties and undermining statutory and constitutional protections. The commission responded that its exemptions were within its rulemaking power, claiming they excluded non-development activities from the CZMA process. The circuit court granted summary judgment for the nonprofit, invalidating the relevant rule sections and restoring the final EA requirement.The Maui Planning Commission and County of Maui appealed. The Supreme Court of the State of Hawaiʻi affirmed the circuit court’s decision. The court held that the commission’s rules exceeded its statutory authority by creating categorical exemptions from the CZMA’s assessment process and unlawfully delegating assessment duties to private parties. The court also found that replacing the final EA with a draft EA undermined required environmental safeguards. The Supreme Court clarified that counties may streamline permitting but cannot eliminate the statutory assessment process or delegate it to applicants. The court affirmed the invalidation of the amended rules. View "Maui Tomorrow Foundation v. Maui Planning Commission" on Justia Law

The case concerns a man accused of kidnapping and sexually assaulting a woman in Maui in 1989. The prosecution’s case relied heavily on circumstantial evidence and expert testimony from an FBI agent, who analyzed hair and fiber samples. The expert testified that hair found in the defendant’s car was “consistent with” originating from the complainant, and that fibers found on her clothing were “consistent with” coming from the car’s seat cover and carpet. The defense challenged the complainant’s credibility but did not contest the expert testimony. The jury convicted the defendant, and he was sentenced to forty years. Nearly thirty years later, a letter from the Department of Justice revealed that the expert’s testimony about hair analysis overstated the science and was invalid. The defense then argued that both the hair and fiber testimony should be deemed unreliable based on scientific developments.The Circuit Court of the Second Circuit held a hearing and found that the hair analysis testimony exceeded the bounds of science but ruled the error harmless beyond a reasonable doubt due to other corroborative evidence. The court did not rule on fiber analysis. The Intermediate Court of Appeals (ICA) affirmed the denial of post-conviction relief, applying the State v. McNulty “newly discovered evidence” test. The ICA found that the fiber testimony was not impeached by the DOJ letter and considered the hair evidence cumulative, so it declined to address whether the new evidence would probably change the result at retrial.The Supreme Court of Hawai‘i reviewed the case and held that when scientific advances later invalidate expert testimony presented at trial, the “false evidence” standard applies, not the “newly discovered evidence” standard. The court found both the hair and fiber testimony materially false, took judicial notice of landmark scientific reports, and concluded there was a reasonable possibility the false evidence contributed to the conviction. The defendant’s due process rights were violated, and the court vacated the lower courts’ decisions, remanding for a new trial. View "Granillo v. State" on Justia Law

On February 12, 2023, a police officer observed the defendant commit multiple traffic violations and attempted a traffic stop. The defendant continued driving for over a mile before stopping at her home. The officer detected signs of intoxication and arrested her after she exited her vehicle, attempted to enter her house, and showed further indications of alcohol use. At the station, her blood alcohol content was found to be over 0.15. She was subsequently charged with operating a vehicle under the influence of an intoxicant as a highly intoxicated driver. The defendant moved to suppress evidence from her warrantless seizure and arrest.The District Court of the Third Circuit initially scheduled a hearing on the suppression motion for April 24, 2023. This was continued at the defendant’s request due to incomplete discovery, rescheduling the hearing to June 16, 2023. The State subpoenaed its primary witness, Officer Molina, nine days before the new hearing date. Four days prior to the hearing, the officer reported he was unavailable due to military training. The State moved to continue the hearing two days before the date, but the district court found the State had not exercised due diligence in securing the witness and denied the motion. Lacking other witnesses, the State could not oppose the suppression motion, and the district court granted suppression of all evidence.The Intermediate Court of Appeals applied its “Lee test” for continuances based on witness unavailability, found the State had exercised due diligence, and vacated the suppression order. On certiorari, the Supreme Court of the State of Hawai‘i held the Lee test is unworkable and should not govern State motions to continue. The court established a new standard: such motions are first analyzed for due diligence under HRPP Rule 48; if due diligence is lacking but the statutory deadline has not expired, courts should use a totality of circumstances “good cause” analysis. Applying this, the court found good cause existed for a continuance and remanded for further proceedings. View "State v. Woody" on Justia Law

After a late-night police pursuit in Makaha, a white Honda being followed by several Honolulu Police Department officers crashed, causing severe injuries to its young occupants. Officer Joshua Nahulu was alleged to have driven the lead pursuit vehicle, with officers Erik Smith, Jake Ryan Bartolome, and Robert Gus Lewis III following. Witness accounts conflicted on whether police vehicles made physical contact with the Honda. However, an expert found no evidence of such contact. None of the officers stopped to render aid after the crash, and they only returned after other emergency responders had arrived. Nahulu was charged under Hawaiʻi’s “fled scene” statute, which requires a driver “involved in a collision” resulting in serious injury or death to stop and render aid. His co-defendants were charged with hindering prosecution and conspiracy.The Circuit Court of the First Circuit denied the defendants’ motions to dismiss, finding the statute’s language—specifically, “involved in a collision”—was not unconstitutionally vague and that the defendants had sufficient notice of the charges. The court ordered the State to clarify, through a bill of particulars, whether it alleged physical contact between Nahulu’s vehicle and the Honda; the State responded that it did not rely on such a theory.On appeal, the Supreme Court of the State of Hawaiʻi held that Nahulu could only challenge the statute as vague as applied to his conduct, not on its face, since the law does not implicate constitutional rights such as free speech. The court further held that “involved in a collision” is not unconstitutionally vague as applied to Nahulu and that the combination of the charging instrument and the bill of particulars provided sufficient notice of the nature and cause of the accusation. The Supreme Court affirmed the circuit court’s denial of the motions to dismiss. View "State v. Nahulu" on Justia Law