Justia Hawaii Supreme Court Opinion Summaries

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In this case concerning the admissibility of a suggestive eyewitness or show-up identification, the Supreme Court set forth new rules and because the holdings apply only prospectively to events occurring after publication of this decision, the Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction. Defendant was charged with one count of burglary in the first degree. Before trial, Defendant filed a motion to suppress a witness's show-up identification. The State stipulated that the procedure employed by the police department was impermissibly suggestive, but the circuit court nonetheless denied the motion, finding the witness's identification sufficiently reliable. The jury then found Defendant guilty as charged. The ICA affirmed. The Supreme Court affirmed but set forth new rules in this opinion regarding whether an eyewitness identification procured through an impermissibly suggestive procedure is nonetheless sufficiently reliable under the totality of the circumstances to be admitted in evidence. View "State v. Kaneaikala" on Justia Law

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The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) affirming the judgment of the circuit court that there were not genuine issues of material fact regarding whether Defendant, Hawaii Medical Service Association (HMSA), acted in bad faith in denying Brent Adams' claim for coverage of an allogenic transplant, holding that there were genuine issues of material fact as to whether HMSA fulfilled its duty of good faith and fair dealing in its handling of Brent's claim. After Brent was diagnosed with stage III multiple myeloma, a life-threatening form of bone marrow cancer, doctors determined that Brent's best chance of survival was first an autologous transplant and then an allogenic transplant. HMSA provided coverage for the first phase of the transplant but denied the claim as to the allogenic transplant. Brent subsequently died. Brent and his wife, Patricia, filed this action alleging that HMSA acted in bad faith in administering Brent's claim for the allogenic transplant. The Supreme Court reversed the lower courts' summary judgment rulings for HMSA, holding that evidence of HMSA's conduct during its relationship with Brent raised genuine issues of material fact as to whether HMSA unreasonably handled Brent's claim for an allogenic transplant. View "Adams v. Hawaii Medical Service Ass'n" on Justia Law

Posted in: Insurance Law
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The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) reversing Defendant's conviction of harassment and affirmed the district court's judgment, holding that Defendant's harassment conviction was supported by substantial evidence. Defendant was charged with harassment stemming from statements he made to a complaining witness (CW), a seventeen-year-old female. CW testified that Defendant made sexually explicit comments to her that made her feel uncomfortable, unsafe, and scared. CW, however, did not explicitly state that she believed Defendant intended to cause her bodily injury, an essential element of the offense charged. The district court determined that Defendant's statements caused CW to believe that Defendant intended to have non-consensual sexual contact with her. The ICA reversed, concluding that there was no evidence that CW reasonably believed Defendant intended to cause her bodily injury. The Supreme Court reversed, holding (1) both elements of harassment and the requisite state of mind were supported by evidence adduced at trial; and (2) Defendant's constitutional challenges were without merit. View "State v. Calaycay" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the trial court's determination that the State breached its constitutional trust duties by failing reasonably to monitor or inspect trust land at issue in this case, holding that an essential component of the State's duty to protect and preserve trust land is an obligation to reasonably monitor a third party's use of the property, regardless of whether the third party has in fact violated the terms of any agreement governing its use of the land. The State leased three tracts of ceded land to the United States for military purposes. Plaintiffs filed a complaint alleging that the State, as trustee of the state's ceded lands, breached its trust duty because it was aware of the possibility that the land leased to the United States contained munitions and explosives but had not taken concrete steps to investigate or ensure the United States's compliance with the lease. The trial court entered judgment in favor of Plaintiffs. The Supreme Court primarily affirmed, holding (1) the circuit court correctly determined that the State did not reasonably monitor the trust property, including the United States' compliance with the lease terms that protect trust property; and (2) the injunctive relief ordered by the circuit court was not entirely suited to remedy the breach. View "Ching v. Case" on Justia Law

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In this suit filed by a mother living on the island of Lana'i and her two school-age daughters, the Supreme Court held that the State was constitutionally required to make all reasonable efforts to provide access to Hawaiian immersion education. Article X, section 4 of the Hawai'i Constitution imposes on the State a duty to provide for a Hawaiian education program in public schools that is reasonably calculated to revive the Hawaiian language. Today, there are Hawaiian immersion schools on five of the major Hawaiian Islands, but no such program exists on the island of Lana'i. Plaintiffs argued that the provision of the Constitution obligating the State to provide for a Hawaiian education program in public schools requires the State to provide her daughters with access to a public Hawaiian immersion education. The Supreme Court agreed and vacated the circuit court's judgment insofar as it granted the State's motion for partial summary judgment, holding that providing reasonable access to Hawaiian immersion education is currently essential to reviving the Hawaiian language, and therefore, it is a necessary component of any program that is reasonably calculated to achieve that goal. View "Clarabal v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction for assault in the second degree, holding that Defendant's constitutional right to confrontation was violated when the circuit court refused to allow cross-examination of the complaining witness on topics relevant to her bias, interest, or motive for testifying against Defendant, and the error was not harmless beyond a reasonable doubt. On appeal, Defendant argued that the trial court erred in refusing to allow him to cross-examine the complaining witness regarding her pending misdemeanor assault charge arising from the same incident for which Defendant was charged, as well as her probation status resulting from a separate assault charge. The Supreme Court agreed, holding that Defendant's constitutional right to confront witnesses was violated, and because the exclusion of the information might have contributed to the jury's decision to convict, the violation of Defendant's right to confrontation was not harmless beyond a reasonable doubt. View "State v. Brown" on Justia Law

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The Supreme Court vacated the decision of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and probation sentence in favor of the State and vacated the circuit court's judgment of conviction and probation sentence, holding that the ICA erred. In 2000, Defendant was convicted and sentenced for charges of sex assault in the second and third degree. Defendant was sentenced to five years of probation and ordered both to complete sex offender treatment and to register as a sex offender. In 2011, Defendant's probation was revoked, and he was resentenced to ten years' confinement. Defendant's sentence for the sex assault convictions expired in 2010. In 2016, Defendant was adjudicated guilty of two counts of failure to comply with covered offender registration requirements. The circuit court sentenced Defendant to a four-year term of probation and ordered, as a special condition of probation, that Defendant participate in a sex offender treatment program. The Supreme Court remanded the matter to the circuit court for resentencing, holding that the ICA erred in affirming based, in part, on its unsubstantiated understanding that Defendant did not previously complete the sex offender treatment program, as ordered. View "State v. Young " on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) vacating the circuit court's order granting Defendant's motion to suppress, holding that the police lacked reasonable suspicion to seize Defendant while he was lying next to the beach in Waikiki. Defendant was approached by police officers while he was lying on a concrete slab adjacent to an apartment complex on Waikiki beach. After an officer asked Defendant to provide his identification and Defendant provided a Veterans Affairs medical card to the officer, the officer noticed Defendant was grasping something in his backpack. An officer pulled the bag from Defendant, and a collapsible baton fell out of the backpack. Defendant grabbed the baton and held it up as if to brandish it, but the police officers wrested control of the baton away from Defendant and arrested him. Defendant was charged with one count of carrying a deadly weapon. The circuit court granted Defendant's motion to suppress evidence of the baton. The ICA vacated the circuit court's order, concluding that the seizure was incident to a valid weapons search. The Supreme Court reversed, holding that the police violated Defendant's constitutional rights by approaching him, asking for his identification, and seizing his backpack. View "State v. Weldon" on Justia Law

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The Supreme Court vacated Defendant's conviction for operating a vehicle under the influence of an intoxicant, holding that the district court erroneously advised Defendant with regard to his right to testify in the context of a consolidated suppression hearing and trial. After he was charged, Defendant filed a motion to suppress statements he allegedly made to the police officer who arrested him. The district court consolidated the hearing on Defendant's motion to suppress with his bench trial and provided Defendant with several advisements about his right to testify. Defendant declined to testify, and the district court granted the motion to suppress in part. The court then found Defendant guilty. The intermediate court of appeals affirmed. The Supreme Court vacated Defendant's conviction and remanded the case for further proceedings, holding that Defendant did not knowingly, intelligently, and voluntarily waive his right to testify for the purposes of the pre-trial suppression hearing. View "State v. Chang" on Justia Law

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The Supreme Court vacated Defendant's conviction, holding that litigants may not utilize another hearsay exception as an alternative to bypass the restrictions contained in the public records hearsay exception. While an exception to the evidentiary rule against hearsay typically allows public records to be admitted into evidence to prove the truth of their contents, the rule contains exclusions that ensure that law enforcement officers testify in person when the contents of their police reports are admitted as evidence in a trial. Another hearsay exception permits previously recorded recollections of a witness to be read into evidence when the witness is unable to sufficiently recall the subject matter of the statements to testify accurately at trial. Defendant was convicted on the sole basis of a police report authored by a law enforcement officer who testified at trial that he could no longer remember the material facts underlying Defendant's arrest. The Supreme Court vacated Defendant's conviction, holding that records excluded by the public records exception cannot be read into evidence based on an alternative evidentiary ground. View "State v. Abrigo" on Justia Law

Posted in: Criminal Law