Justia Hawaii Supreme Court Opinion Summaries

This case arose from a dispute over a flag lot parcel of land in Puko’o, located on the Island of Moloka’i, County of Maui, State of Hawaii. At issue before the Supreme Court was whether an order deciding a motion that was purportedly filed pursuant to Haw. R. Civ. P. 60(b) is appealable where the underlying ruling from which the party sought Rule 60(b) relief was not appealable. The Intermediate Court of Appeals (ICA) dismissed the appeal for lack of appellate jurisdiction, concluding that the order regarding the Rule 60(b) motion was not appealable because the circuit court had not entered a valid final judgment on the underlying claims at issue. The Supreme Court affirmed, holding that relief under Rule 60(b) requires an underlying judgment that comports with the principles of finality set forth in Jenkins v. Cades Schutte Fleming & Wright, and therefore, the ICA did not err in including that it lacked appellate jurisdiction to review the order regarding the Rule 60(b) motion. View "Bailey v. Duvauchelle" on Justia Law

Plaintiff filed a complaint against Defendant in a state district court and later moved to dismiss the case. The district court granted the motion to dismiss without prejudice and awarded Defendant attorney’s fees pursuant to Hawai’i District Rules of Civil Procedure 41(a)(2), which grants a trial court discretion to impose attorney’s fees as a term or condition of voluntary dismissal. Plaintiff appealed, arguing that the district court erred in granting attorney’s fees before the merits of the case had been decided and before a prevailing party was properly identified. The intermediate court of appeals (ICA) affirmed, concluding that the district court did not err in awarding Defendant attorney’s fees in order to alleviate any prejudice resulting from the dismissal. The Supreme Court vacated the lower courts’ judgments and the award of attorney’s fees and costs, holding that the district court abused its discretion by (1) not providing Plaintiff with an opportunity to choose between accepting this condition or withdrawing her motion to dismiss; and (2) failing to evaluate and make findings on whether the award and amount of attorney’s fees and costs accords substantial justice to both parties. View "Tagupa v. VIPDesk" on Justia Law

The Planning Director of the County of Hawaii approved the application of Michael Pruglo to consolidate and resubdivide the pre-existing lots on his forty-nine-acre parcel of land. Mark Kellberg, who owned land adjacent to the subject property, objected to the approval. Kellberg brought suit against the Planning Director and the County of Hawaii seeking to have the subdivision declared void. The intermediate court of appeals (ICA) ruled that the Planning Director’s approval of Pruglo’s subdivision was invalid because it increased the number of lots. The Supreme Court vacated the judgment of the ICA, holding that the ICA erred in ruling on the merits of Kellberg’s claims without addressing whether the owners of the lots within the subject property were required to be joined as parties under Haw. R. Civ. P. 19. Because the lot owners were necessary parties under Rule 19(a), the Court remanded the case to the circuit court with instructions to order the joinder of the lot owners under Rule 19. View "Kellberg v. Yuen" on Justia Law

This appeal arose from a property title dispute between Defendant, who purchased the property in 2007, and Plaintiff, which later acquired a quitclaim deed to the property following a judicial foreclosure. After Defendant refused to vacate the property, Plaintiff filed the underlying action, requesting a judgment for immediate and exclusive possession of the property and a writ of possession. The circuit court entered an order granting Plaintiff’s motion for summary judgment and issued a writ of possession. Defendant filed post-judgment motions and then filed a notice of appeal from the summary judgment. The circuit court denied Defendant’s post-judgment motions. The intermediate court of appeals (ICA) vacated the summary judgment and remanded based on Defendant’s post-judgment declaration. The Supreme Court vacated the ICA’s judgment and remanded, holding that the ICA erred in relying upon Defendant’s post-judgment motion as a basis to find disputed facts with regard to the motion for summary judgment. View "Kondaur Capital Corp. v. Matsuyoshi" on Justia Law