Justia Hawaii Supreme Court Opinion Summaries

After a trial, Defendant was convicted of operating a vehicle after license and privilege have been suspended or revoked for operating a vehicle under the influence of an intoxicant. On appeal, the intermediate court of appeals (ICA) vacated the district court’s judgment, determining that the charge against Defendant was defective for failing to allege the requisite state of mind, and remanded with instructions to dismiss the case without prejudice. Defendant filed an application for writ of certiorari, contending that the ICA gravely erred in failing to address his arguments that insufficient evidence sustained the conviction and that double jeopardy precluded retrial. The Supreme Court affirmed but on different grounds, holding (1) a reviewing court is required to address an express claim of insufficiency of the evidence prior to remaining for a new trial based on a defective charge; but (2) substantial evidence supported the conviction in this case, and therefore, double jeopardy did not preclude a retrial. View "State v. Davis" on Justia Law

Homeowners filed a complaint against the County and certain Developers, alleging that the Mayor had unlawfully exempted certain projects from a height restriction law (“Law”). On December 31, 2008, the circuit court granted partial summary judgment in favor of Homeowners and entered an order for declaratory and injunctive relief. The circuit court subsequently denied Homeowners’ request for attorneys’ fees under the private attorney general doctrine. After the parties appealed, the Maui County Council passed a bill making the Mayor’s previously illegal conduct legal. The intermediate court of appeals (ICA) (1) vacated the circuit court’s December 31, 2008 order because the Law issue was frustrated based on mootness, and (2) concluded that the circuit court did not abuse its discretion in denying attorneys’ fees. The Supreme Court (1) vacated that portion of the ICA’s judgment that vacated the circuit court’s judgments and order, holding (i) when a case is mooted while on appeal, the appellate could should remand the case to the trial court for a consideration of the vacatur issue, and (ii) the ICA did not properly analyze the vacatur issue; and (2) affirmed that portion of the ICA’s judgment that affirmed the circuit court’s denial of Homeowners’ request for attorneys’ fees. Remanded. View "Goo v. Arakawa" on Justia Law

Defendant John Walton and his codefendant, Courage Lee Elkshoulder, were indicted for attempted murder in the second degree and robbery in the first degree. The circuit court consolidated Walton’s and Elkshoulder’s trials and denied Walton’s and Elkshoulder’s motions for severance. During trial, Walton and Elkshoulder each argued that the other had stabbed the complaining witness. The jury found Walton guilty of both attempted murder and robbery but found Elkshoulder guilty only of assault and robbery. The Supreme Court vacated the circuit court’s judgment and remanded for a new trial, holding that the circuit court erred in denying Walton’s motion for severance, and, under the circumstances, Walton was prejudiced and denied a fair trial. View "State v. Walton" on Justia Law

Plaintiff brought a claim against the State Procurement Policy Board challenging the validity of Haw. Admin. R. 3-122-66, claiming it was contrary to the “minimum of three” persons requirement in Haw. Rev. Stat. 103D-304(g) and should be struck down. Plaintiff also sought a declaration that every government contract issued under the invalid authority of Rule 3-122-66 was void ab initio. The circuit court concluded that Plaintiff had standing to bring the action and that Rule 3-122-66 was invalid, but the court declined invalidate all contracts issued under Rule 3-122-66. Both parties appealed. The Supreme Court affirmed, holding (1) Petitioner had standing to bring his claim based on his status as an “interested person” and in order to satisfy the “needs of justice”; (2) Rule 3-122-66 is invalid because manifestly exceeds the scope of authority given by the legislature to the Board; and (3) the circuit court did not err in refusing to rule that every government contract issued under Rule 3-122-66 was void ab initio. View "Asato v. State Procurement Policy Bd." on Justia Law

Plaintiff filed a complaint against his former employer and supervisors, alleging that he suffered discriminatory conduct while employed as a car salesman. Plaintiff asserted claims for state harassment and retaliation, federal harassment and retaliation, unlawful termination as against public policy, and breach of his employment contract. The circuit court granted summary judgment in favor of Defendants. The intermediate court of appeals (ICA) (1) vacated the grant of summary judgment in favor of the employer and one of Defendant’s supervisors on the state harassment and retaliation claims and vacated the grant of summary judgment in favor of the employer on the federal harassment and retaliation claims and the public policy claim, and (2) otherwise affirmed. The Supreme Court (1) vacated the ICA’s judgment on the state harassment and retaliation claims with respect to Plaintiff’s supervisor, holding that individual employees are not liable as employers under Haw. Rev. Stat. 378-2(1)(A) and 378-2(2); and (2) otherwise affirmed. View "Lales v. Wholesale Motors Co." on Justia Law

The State charged Defendant, a native Hawaiian, of operating a vehicle under the influence of an intoxicant (OVUII). Defendant appealed, arguing, among other things, that he was denied due process because the complaint did not allege the state of mind that the State was required to prove for the charge of OVUII. The intermediate court of appeals (ICA) affirmed Defendant’s conviction. The Supreme Court vacated the ICA’s judgment and vacated the circuit court’s judgment of conviction and sentence, holding that, inasmuch as the charge against Defendant did not allege the requisite state of mind that also was an essential fact of the offense of OVUII, the complaint must be dismissed without prejudice. Remanded with instructions to dismiss. View "State v. Rivera " on Justia Law

Petitioner was adjudged guilty of operating a vehicle under the influence of an intoxicant in violation of Haw. Rev. Stat. 291E-61(a)(1). Petitioner challenged the sufficiency of the complaint against her for the first time on appeal, alleging that section 291E-61(a)(1) was deficient for failing to allege mens rea. The intermediate court of appeals affirmed the district court’s judgment. The Supreme Court vacated the ICA’s judgment and remanded with instructions to dismiss the complaint against Petitioner without prejudice, holding that because the complaint failed to charge a requisite state of mind, the ICA’s judgment must be vacated and the charge dismissed without prejudice because it violated due process. View "State v. Avilla " on Justia Law

Defendant was charged with committing the offense of assault in the third degree and was convicted as charged. Defendant appealed, arguing that he was not adequately informed of his right to testify. The Supreme Court reversed and remanded for a new trial, holding (1) the district court’s right-to-testify colloquy was defective, and as a result, Defendant did not intelligently, knowingly, and voluntarily waive his right to testify; (2) the constitutional violation of Defendant’s right to testify was not harmless beyond a reasonable doubt; and (3) substantial evidence supported Defendant’s conviction, and the prohibition against double jeopardy did not preclude a retrial in this case. View "State v. Pomroy" on Justia Law

After a bench trial, Petitioner was convicted of abuse of a family or household member. On appeal, Petitioner argued that the family court did not ensure that he had “fully” waived his right to a jury trial. The intermediate court of appeals (ICA) affirmed, concluding that under the totality of the circumstances, Petitioner had validly waived his right to a jury trial. The Supreme Court vacated the ICA’s judgment and the family court’s judgment, holding that the family court failed to ensure that Petitioner’s waiver of his right to a jury trial was voluntary. Remanded for a new trial. View "State v. Baker" on Justia Law

Petitioners executed a promissory note secured on a mortgage on their residence from a California corporation. The mortgage stated that Respondent, Mortgage Electronic Registration Systems, listed as mortgagee and nominee, held legal title to the interests granted by Petitioners in the mortgage. After Petitioners failed to make payments pursuant to the terms of the note, Respondent, acting as nominee, filed a complaint against Petitioners seeking foreclosure of the mortgage and sale of the property. The circuit court granted Respondent's motion for summary judgment and entered a foreclosure judgment. Petitioners' property was then sold to Respondent. The circuit court confirmed the sale despite Petitioners' assertion that Respondent lacked standing to bring the foreclosure action. The intermediate court of appeals affirmed. The Supreme Court affirmed, holding that Petitioners were precluded from raising the issue of Respondent's standing where (1) a standing objection is not unique to a confirmation of sale proceeding from which Petitioners appealed; and (2) Petitioners' failure to appeal the foreclosure judgment barred challenges to Respondent's standing under the doctrine of res judicata.View "Mortgage Elec. Registration Sys., Inc. v. Wise" on Justia Law