Justia Hawaii Supreme Court Opinion Summaries

Two brothers, Roland and Robert, ran an automotive business together under Guieb Inc. Their relationship deteriorated when Robert made decisions that Roland disagreed with, including using their company for his own benefit and allegedly stealing the trade name and most profitable shop for his personal companies. Roland sued Robert, alleging unfair and deceptive trade practices, unfair methods of competition, and deceptive trade practices under Hawaii Revised Statutes (HRS) §§ 480-2 and 481A-3. He also sought punitive damages for fraud, misrepresentation, nondisclosure, and breach of fiduciary duty.The Circuit Court of the First Circuit granted Robert’s motion for partial summary judgment (MPSJ) and dismissed Roland’s claims under count 12, finding no genuine issue of material fact. The court also granted Robert’s motion for judgment as a matter of law (JMOL) on punitive damages, preventing the jury from considering them. Additionally, the court ruled that brotherhood did not establish a fiduciary duty, granting Robert’s MPSJ on that issue as well.The Intermediate Court of Appeals (ICA) reversed the circuit court on three issues. It held that Roland’s unfair and deceptive trade practices claim should have gone to the jury, as there was evidence that Robert represented Guieb Inc. and Guieb Group as the same entity. The ICA also held that the jury should have considered punitive damages, given the evidence of Robert’s actions that could justify such damages. Lastly, the ICA found that brotherhood created a kinship fiduciary duty, which should have been considered by the jury.The Supreme Court of Hawaii agreed with the ICA that the jury should have considered Roland’s claims under count 12 and punitive damages. However, it disagreed that kinship created a fiduciary duty, affirming the circuit court’s MPSJ on that issue. The case was remanded for further proceedings consistent with the opinion. View "Guieb v. Guieb" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the intermediate court of appeals (ICA) partially vacating the circuit court's judgment entering judgment against Plaintiffs in this action alleging that Defendants intentionally misrepresented the value of a limousine service, holding that some of the rulings of the trial court in this complex commercial dispute involving the sale of the business were in error.The Lacy Parties represented Goran and Ana Maria Pleho in purchasing the business. The transaction was completed in the name of Goran PLeho LLC (GPLLC). After the purchase, the Plehos and GPLLC (collectively, Pleho Parties) sued, alleging that Lacy Parties intentionally misrepresented the value of the business. The Supreme Court (1) vacated the circuit court's dismissal of Pleho Parties' intentional infliction of emotional distress and negligent infliction of emotional distress claims and the court's grant of judgment as a matter of law in favor of Lacy Parties on GPLLC's fraud and punitive damages claims; (2) vacated the ICA's judgment to the extent that it vacated the circuit court's order denying Lacy Parties' motion in limine; and (3) vacated the ICA's judgment to the extent that it affirmed the grant of summary judgment in favor of Lacy Parties on the Pleho's unfair and deceptive trade practices claim. View "Goran Pleho, LLC v. Lacy" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court’s order and granting summary judgment for Defendant in this case arising out of the uncompleted sale of one business to another, holding that the plaintiff raised genuine issues of material fact as to its unfair method of competition (UMOC) claim.Specifically, the Court held (1) to raise an issue of material fact as to the nature of the competition requirement of a UMOC claim following the close of discovery, a plaintiff must demonstrate that the defendant’s alleged anticompetitive conduct could negatively affect competition, but the plaintiff need not prove that the defendant in fact harmed competition; (2) to survive summary judgment, a plaintiff may generally describe the relevant market without resort to expert testimony and need not be a competitor of or in competition with the defendant; and (3) the plaintiff in this case raised genuine issues of material fact as to the first and second elements of a UMOC claim, and the circuit court erred erred in holding that the plaintiff was estopped from asserting the UMOC claim based on waiver, judicial estoppel and collateral estoppel. View "Field v. National Collegiate Athletic Ass’n" on Justia Law