Justia Hawaii Supreme Court Opinion Summaries

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

Appellant, an inmate in custody, filed a petition post-conviction relief under Haw. R. Penal P. 40, alleging that he was incompetent to stand trial, his trial counsel and appellate counsel provided ineffective assistance, and prosecutorial misconduct. The circuit court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that Appellant’s appeal was without merit where Appellant failed to establish a colorable claim that (1) he was incompetent to stand trial; (2) his appellate counsel provided ineffective assistance for failing to appeal the issue of Appellant’s alleged incompetence to stand trial; (3) his trial counsel was ineffective; and (4) the prosecutor committed misconduct that would warrant relief under Rule 40. View "Fanelli v. State " on Justia Law

United Public Workers, AFSCME, Local 646, AFL-CIO (“UPW”) filed an action on behalf of the employees it represented, alleging (1) then-Governor Lingle and members of her administration retaliated against UPW members for filing a lawsuit opposing her statewide furlough plan; and (2) the State was unlawfully privatizing positions customarily performed by civil servants under the merit system. The circuit court dismissed the complaint based on a lack of jurisdiction. The intermediate court of appeals (ICA) vacated the circuit court’s judgment and remanded with instructions to stay the action pursuant to the primary jurisdiction doctrine so the parties could pursue appropriate administrative remedies before the Hawaii Labor Relations Board (HLRB). The Supreme Court primarily affirmed, holding (1) the ICA did not err in concluding that the primary jurisdiction doctrine was applicable to UPW’s retaliation claims because the claims required the resolution of issues that have been placed within the special competence of the HLRB, and that a stay, rather than a dismissal, was appropriate under the circumstances; and (2) the primary jurisdiction doctrine did not apply to UPW’s privatization claims, and therefore, the circuit court erred in dismissing these claims, and the ICA erred in referring the claims to the HLRB. Remanded. View "United Pub. Workers, AFSCME, Local 636, AFL-CIO v. Abercrombie" on Justia Law

Richard Cohan sued Marriott Hotel Services and RRB Restaurants for damages he incurred when he was injured at a restaurant at Marriott’s. The case was placed in the Court Annexed Arbitration Program. Marriott asked Cohan to sign authorizations to obtain medical and employment records, but Cohan refused. Marriott subsequently moved for an order compelling Cohan to sign the authorizations so it could obtain the records via subpoena. The arbitrator ordered Cohan to sign the authorizations as well as a qualified protective order. The order, however, did not limit the use or disclosure of Cohan’s health information to the underlying litigation. The Honorable Bert Ayabe, the arbitration judge, affirmed the arbitrator’s decision. Petitioner subsequently filed a petition for writ of mandamus. The Supreme Court granted the petition and ordered Judge Ayabe to vacate the order affirming the arbitration decision and order that the qualified protective order and the authorizations for release of medical records be revised consistent with this opinion, holding that the privacy provision of Haw. Const. art. I, 6 protected Cohan’s health information against disclosure outside the underlying litigation. View "Cohan v. Circuit Court (Ayabe)" on Justia Law