Justia Hawaii Supreme Court Opinion Summaries

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The Supreme Court answered three modified questions certified to it by the United States District Court for the District of Hawai'i in a federal court lawsuit where a grantor asserted that an escrow company's alleged deletion of an easement from the property description attached to a deed he executed rendered the deed a forged deed that was void ab initio and the escrow company and grantee asserted that the grantor's claim sounded in fraud and was barred by a statute of limitations. The Supreme Court held (1) a deed is void ab initio for fraud such that a claim challenging the validity of the deed is not subject to a statute of limitations under certain circumstances; (2) the six-year "catch-all" statute of limitations under Haw. Rev. Stat. 647-1(4) applies to a claim that a deed was procured by fraud of the type that does not render it void ab initio, such as fraud in the inducement and constructive fraud; and (3) the statute of limitations begins to run on a grantor's claim that a deed was procured by fraud of the type that does not render it void ab initio when the grantor discovers or should have discovered the existence of the claim or the person liable for the claim. View "Hancock v. Kulana Partners, LLC" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) determining that the State's complaint was sufficient and sustaining that the State's "golden rule" objection, holding that the complaint was defective and that the "golden rule" argument did not apply. Defendant was convicted of obstructing. The ICA vacated the conviction and remanded for a new trial, holding that there was an error in the jury instructions. On certiorari, Defendant asked the Supreme Court to determine whether the ICA erred in determining that the State's complaint was sufficient despite its failure to define the statutory term "obstructs" and whether the ICA erred in analyzing a golden rule objection made by the State during Defendant's closing argument. The Supreme Court remanded the case to the circuit court to dismiss the obstructing charge, holding (1) by omitting an essential element of the offense of obstructing, the complaint was insufficient; and (2) while the ICA correctly concluded that the circuit court erred in sustaining the State's objection to defense counsel's closing argument, it incorrectly analyzed whether that error was harmless. View "State v. Kauhane" on Justia Law

Posted in: Criminal Law
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In this case involving $537,000 in excess foreclosure sale proceeds the Supreme Court vacated the judgment of the intermediate appellate court (ICA) and the circuit court's final judgment in favor of Respondents, holding that the circuit court's determination that Petitioners could have reasonably known of certain transfers and their fraudulent nature on or before February 21, 2005 contravened this Court's ruling in Schmidt II. Petitioners obtained a final judgment for the excess proceeds but later learned that those same proceeds were already transferred. Petitioners then brought a complaint alleging that the proceeds were fraudulently transferred. The circuit court entered judgment in favor of Respondents. The ICA concluded that Petitioners' claim under Hawai'i Uniform Fraudulent Transfer Act (HUFTA), Haw. Rev. Stat. Chapter 651 C, should have been dismissed as untimely. The Supreme Court vacated the judgment, holding that the ICA incorrectly held that the statute of limitations ran from the date of the transfer rather than from the date that Petitioners discovered the fraudulent nature of the transfer. On remand, the circuit court concluded that Petitioners' claims were time barred. The ICA affirmed. The Supreme Court reversed, holding that the statute of limitations for Petitioners' HUFTA claim did not begin until July 26, 2005, and therefore, Petitioners timely raised their claims. View "Schmidt v. HSC, Inc." on Justia Law

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The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) affirming the circuit court's order denying Petitioner's petition to vacate, set aside, or correct judgment or to release Petitioner from custody, holding that Petitioner's Haw. R. Pen. P. 40 petition stated a colorable claim that the Hawai'i Paroling Authority (HPA) violated his due process rights. Petitioner pleaded guilty to manslaughter and firearms offenses. In his Rule 40 petition, Petitioner argued that the HPA arbitrarily and capriciously determined that he was a Level III offender for purposes of calculating his minimum term of imprisonment on his manslaughter conviction. The circuit court denied the petition without holding a hearing. The ICA affirmed. The Supreme Court vacated the judgment in part and remanded the case, holding (1) Petitioner raised a colorable claim that the HPA arbitrarily and capriciously maintained Petitioner's level of punishment at Level III on the manslaughter conviction; and (2) Petitioner raised a colorable claim that the circuit court provided inadequate reasons for imposing consecutive sentences. View "Lewi v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated Defendant's conviction and remanded the case for further proceedings, holding that the trial court erred in determining that Defendant's confession was voluntarily made despite an interrogating officer informing him, untruthfully, that he did not pass a polygraph test, holding the deliberate falsehood regarding the polygraph results impermissibly tainted Defendant's confession. The trial court admitted Defendant's confession into evidence over defense objection. The court further ruled that during Defendant's trial testimony, when discussing the circumstances of his confession, could not mention the words "polygraph" or "test" or that the interrogating officer gave him inaccurate test results before his confession was elicited. The Supreme Court vacated the conviction, holding (1) the admission of Defendant's confession was not harmless error; (2) the exclusion of evidence of the circumstances surrounding the eliciting of Defendant's confession severely compromised Defendant's constitutional right to a fair trial and to present a complete defense; and (3) the court's jury instruction that defined an element of the charged offense contained a misstatement of law and was ambiguous and incomplete. View "State v. Matsumoto" on Justia Law

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In this appeal arising from a 2014 petition by the Bank of Hawai'i (BOH) to resign as trustee for a trust comprised of several parcels of land underlying the Discovery Bay condominium complex in Waikiki, the Supreme Court vacated in part and affirmed in part the intermediate court of appeals' (ICA) judgment on the appeal, holding that the ICA erred when it decided that Michael David Bruser and Lynn Bruser were liable for the trustee's fees. The Brusers, who held the leasehold commercial unit in the condominium, and several trust beneficiaries objected to BOH's petition to resign as trustee. The probate court permitted BOH to reform the trust agreement and determined that a $9,850 monthly trustee's fee was reasonable. The ICA determined that the Brusers were responsible for paying the trustee's fees and that the monthly trustee's fee was reasonable. The Supreme Court held (1) the ICA erred in concluding that the Brusers were liable for the trustee's fees when the probate court did not address the issue; and (2) the ICA properly affirmed the probate court's conclusion that a $9,850 monthly trustee's fee was reasonable. View "In re Trust Agreement dated June 6, 1974" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the judgment of the district court accepting Defendant's pleas of no contest to open lewdness and disorderly conduct, holding that the trial judge erred in denying Defendant's oral motion to defer the acceptance of her no contest plea (motion for DANC). The State and Defendant reached an agreement where Defendant would plead no contest to the charges against her, the State would recommend five days of jail time and would not object to a subsequent motion for DANC, provided that Defendant be placed on unsupervised probation for six months. After Defendant made an oral motion for DANC the district court denied the motion on the basis that Defendant did not wish to stay in Hawaii during the six-month probation period. The ICA affirmed. The Supreme Court vacated and remanded, holding that the district court abused its discretion in denying Defendant's motion for DANC where defense counsel stated that Defendant would be willing to return to Hawaii and the court did not specifically consider the factors described in Haw. Rev. Stat. 853-1. View "State v. Phillips " on Justia Law

Posted in: Criminal Law
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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