Justia Hawaii Supreme Court Opinion Summaries

Passed by voter initiative, the “Lowest Law Enforcement Priority of Cannabis” (LLEP) of the Hawai’i County Code provides that the cultivation, possession and use for adult personal use of cannabis shall be the lowest law enforcement priority for law enforcement agencies in the county. Petitioners, a group of pro se individuals, filed a complaint alleging that Defendants - members of the Hawai’i County Council, Hawai’i County prosecutors, and chief of police - failed to comply with the LLEP. The circuit court granted Defendants’ motions for judgment on the pleadings and dismissed the case, concluding that the LLEP was preempted by state law. The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the LLEP is preempted solely because it conflicts with state law; and (2) the entire LLEP is invalidated because it conflicts with, and is therefore preempted by, state law. View "Ruggles v. Yagong" on Justia Law

After a jury trial, Defendant was found guilty of theft of the proceeds of sale of the home of an individual for whom she was acting as a caregiver, changing the name of ownership of two joint accounts, and taking $8,000 from the joint account to pay off Chin’s car. Defendant filed a motion for a new trial, arguing that the actions of a jury foreperson in communicating with a main defense witness about possible employment was highly prejudicial. The circuit court denied the motion, concluding that the nature of the alleged deprivation did not rise to the level of being substantially prejudicial. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment on appeal and the judgment of conviction and sentence, holding (1) in this case, the circuit court was required to investigate the circumstances surrounding the nontrivial communication between the defense witness and the juror; and (2) because the circuit court did not conduct such an investigation, it could not be said that Defendant’s fundamental right to a fair trial by an impartial jury was not compromised. Remanded for a new trial. View "State v. Chin" on Justia Law

After a jury trial, Defendant was found guilty of assault in the first degree and sentenced to ten years in prison. Defendant appealed, arguing that the circuit court abused its discretion in denying his motion to substitute retained counsel in place of his court-appointed counsel. The intermediate appellate court (ICA) affirmed the conviction and sentence, concluding that the circuit court did not abuse its discretion in denying Defendant’s motion. The Supreme Court vacated the ICA’s judgment on appeal and the circuit court’s judgment of conviction and sentence, holding that the circuit court abused its discretion in denying Defendant’s motion for withdrawal and substitution of counsel, resulting in the denial of Defendant’s right to privately retained counsel of choice under Haw. Const. art. I, 14. Remanded for a new trial. View "State v. Reed" on Justia Law

Appellants - State Representative Bob McDermott, Garret Hashimoto, William E.K. Kumia, and David Langdon - filed suit to invalidate the Hawai’i Marriage Equality Act of 2013, which changed Hawaii’s definition of marriage so that same-sex couples could marry. The circuit court upheld the Act’s validity and granted summary judgment for Appellees - the Governor and the Director of the Department of Health. Appellants appealed, arguing that the 2013 Act was unconstitutional under Haw. Const. art. I, 23, which provides that the “legislature shall have the power to reserve marriage to opposite-sex couples.” The Supreme Court vacated the circuit court’s order and remanded with instructions to dismiss the case for want of jurisdiction, holding that Appellants lacked standing to bring this lawsuit, as moral or ideological disapproval to same-sex marriage does not constitute a legally cognizable injury sufficient to establish standing. View "McDermott v. Ige" on Justia Law

After a jury trial, Petitioner was convicted of terroristic threatening in the second degree and kidnapping. The Intermediate Court of Appeals affirmed Petitioner’s conviction and sentence. The Supreme Court reversed, holding that the circuit court erred in (1) instructing the prosecutor to inform the jury during closing arguments that the complaining witness was unavailable because she was dead - a fact not in evidence - and the error was not harmless beyond a reasonable doubt; and (2) admitting the complaining witness’s preliminary hearing testimony at trial in violation of Petitioner’s right to confrontation, and the error was not harmless. Remanded for a new trial. View "State v. Nofoa" on Justia Law

In 1994, Investors Equity Life Insurance Company of Hawaii, Ltd. (IEL) was liquidated. The State Insurance Commission was appointed as IEL’s liquidator (Liquidator). In 1996, Investors Equity Life Holding Company (IELHC), the former parent company and sole shareholder of IEL, surrendered all of its shares in IEL to the Commissioner as part of a settlement agreement to resolve claims relating to IEL’s insolvency. The Liquidator proceeded to administer IEL’s estate. In 2008, IELHC wrote to the Liquidator claiming that it held legal or equitable title to all of IEL’s stock and demanding that the Liquidator turn over to IELHC all shares and assets remaining in IEL’s estate. The Liquidator denied the claim. The circuit court affirmed. The Supreme Court affirmed, holding (1) the circuit court did not err in concluding that IELHC asserted a claim against IEL’s estate and that the claim was time barred; (2) the circuit court had subject matter jurisdiction over IELHC’s claim and personal jurisdiction over IELHC; (3) there were no grounds for abating the adjudication of IELHC’s claim; and (4) the circuit court’s procedures met due process requirements. View "Ito v. Investors Equity Life Holding Co." on Justia Law

Plaintiff applied for a position with CDM Media, USA, Inc. Plaintiff was not hired for the position. Thereafter, Plaintiff filed a complaint alleging that CDM had decided not to hire her because of her age, and therefore, she had been subjected to employment discrimination. The circuit court granted summary judgment for CDM, concluding that Plaintiff had failed to demonstrate that CDM’s reasons for not hiring her were pretextual. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court vacated the judgments of the lower courts, holding that the trial court erred in granting summary judgment, as CDM did not satisfy its burden to produce a legitimate, nondiscriminatory reason for declining to hire Plaintiff. View "Adams v. CDM Media USA, Inc." on Justia Law

Defendant was indicted in counts I and III upon the charge of electronic enticement of a child in the first degree in violation of Haw. Rev. Stat. 707-756. Defendant moved to dismiss counts I and III, arguing that section 707-756 violates the dormant commerce clause and that the statute is unconstitutionally overbroad and vague. The trial court denied the motions to dismiss. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) based upon the plain language of section 707-756, its legislative history, and principles of statutory construction, the felonious intent of the statute applies only to the agreement element of that statute; and (2) the statute is not unconstitutionally overbroad or vague, and its application does not violate the dormant commerce clause. View "State v. Alangcas" on Justia Law

After a trial, Defendant was convicted of committing the offense of prostitution. Defendant appealed, contending that there was insufficient evidence to prove the commission of a prostitution offense. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed the judgment on appeal of the ICA and clarified the prior-to-trial advisement required by State v. Lewis, holding (1) the ICA did not err in concluding that the evidence adduced at trial was sufficient to sustain Defendant’s conviction; (2) in order to more fully protect the right not to testify under the Hawaii Constitution, trial courts when informing the defendant of the right not to testify during the pretrial advisement must also advise the defendant that the exercise of this right may not be used by the fact finder to decide the case; and (3) although the court’s prior-to-trial advisement in this case did not inform Defendant that his silence could not be used against him if he did not testify, there was no error premised on the lack of judicial notice. View "State v. Monteil" on Justia Law

Defendant was charged with assault against a law enforcement officer in the second degree, resisting arrest, and disorderly conduct. Before trial, the circuit court denied defense counsel’s motion for withdrawal and substitution of counsel. A jury found Defendant guilty of the three charges. The Intermediate Court of Appeals affirmed, holding that the circuit court did not abuse its discretion in (1) denying Defendant’s motion for withdrawal and substitution of counsel, and (2) failing to sua sponte hold a hearing to determine Defendant’s competence to stand trial. The Supreme Court vacated the judgments of the lower courts, holding that, under the circumstances of this case, the circuit court (1) committed prejudicial error in denying Defendant’s motion for withdrawal and substitution of counsel; and (2) abused its discretion in not ordering a fitness examination. View "State v. Harter" on Justia Law