Justia Hawaii Supreme Court Opinion SummariesArticles Posted in Health Law
State v. Abella
At issue was whether Defendant could be convicted of homicide if the victim's death was the immediate result of the victim's family's choice to withdraw medical care. The Supreme Court vacated Defendant's conviction of manslaughter and remanded the case for a new trial, holding that the circuit court committed plain error by failing to instruct the jury on causation and culpability pursuant to Haw. Rev. Stat. 702-215 and 207-216. After Defendant severely beat the victim, the victim was comatose for more than a week. Twelve days later, the victim was removed from life support and declared dead. A jury found Defendant guilty of manslaughter. The Supreme Court reversed, holding (1) Haw. Rev. Stat. 327E-13(b), a provision in the Uniform Health-Care Decisions Act, which prohibits designated as a homicide any "[d]eath resulting from the withholding or withdrawal of health care" under the Act, did not shield Defendant from conviction; and (2) the jury should have been given instructions on causation pursuant to sections 702-215 and 702-216, which would have enabled the jury to consider whether the intervening volitional conduct of the medical team and family interrupted the chain of causation between Defendant's actions and the victim's death such that it would be unjust to convict Defendant of homicide. View "State v. Abella" on Justia Law
Yukumoto v. Tawarahara
Health insurers do not have a broad, unrestricted right of subrogation against third-party tortfeasors who cause injury to their insureds but, rather, are limited to reimbursement rights established by statute. In this personal injury case, the circuit court ruled that Haw. Rev. Stat. 663-10 and/or Haw. Rev. Stat. 431:13-103(a)(1) abrogated Hawai’i Medical Service Association’s (HMSA) contractual and common law rights in subrogation against a third-party tortfeasors responsible for injury to its insured. The Supreme Court affirmed, holding (1) a health insurer does not have equitable subrogation rights against a third-party tortfeasor in the context of personal injures; (2) a health insurer’s subrogation and reimbursement rights are limited by section 663-10 and section 431-13:103(a)(1); (3) any contractual provision that conflicts with section 663-10 is invalid; and (4) section 663-10 takes precedence over HMSA’s subrogation rights. View "Yukumoto v. Tawarahara" on Justia Law
Pacific Radiation Oncology, LLC v. Queen’s Med. Ctr.
Plaintiffs - Pacific Radiation Oncology LLC (PRO) and several doctors - sued Queens Medical Center (QMC), which provided radiation oncology therapy services to patients of PRO using equipment and services provided by QMC, after QMC notified Plaintiffs that only physicians employed by QMC could provide professional radiation oncology services at QMC. QMC counterclaimed, alleging that Plaintiffs steered cancer patients away from QMC in violation of unfair competition principles. During litigation, QMC’s law firm publicly filed a list naming 132 patients PRO was alleged to have diverted. The patients were not parties to the underlying lawsuit, but nineteen of them were granted intervenor status. Plaintiffs moved for a temporary restraining order or preliminary injunction to prevent further violations of patient privacy. The magistrate judge found the 132 cancer patients’ confidential medical records to be relevant to the parties’ claims and counterclaims. On appeal, the district court certified questions to the Supreme Court. The Supreme Court answered (1) pursuant to Haw. Const. art. I, 6 the parties cannot use or be compelled to produce confidential patient medical records, even if sufficiently de-identified, in litigation where the patient is not a party; and (2) that provision protects the health information of the patient intervenors to this case. View "Pacific Radiation Oncology, LLC v. Queen’s Med. Ctr." on Justia Law
Posted in: Health Law
State v. Haw. Gov’t Employees Ass’n
The State filed a third amended complaint seeking a declaratory judgment that public funds ported to certain unions under the Hawaii Public Employees Health Fund’s porting program exceeded the amounts allowed by law. The circuit court’s declaratory ruling interpreting the statutory phrase “actual monthly cost of the coverage” in Haw. Rev. Stat. 87 essentially ended the State’s case, and the court entered judgment against the State. The intermediate court of appeals affirmed. The Supreme Court affirmed, holding (1) the circuit court did not err in interpreting “actual monthly cost of the coverage,” and (2) the State’s factual allegations did not constitute a violation of the provisions of chapter 87. View "State v. Haw. Gov’t Employees Ass’n" on Justia Law
Siopes v. Kaiser Found. Health Plan, Inc.
Respondents in this case included Kaiser Foundation Health and Kaiser Foundation Hospitals (collectively, Kaiser). Michael Siopes, a public school teacher, enrolled in a Kaiser health plan offered through the Hawaii Employer-Union Health Benefits Trust Fund (EUTF). Michael was later diagnosed with cancer by a Kaiser medical professional. Michael and his wife, Lacey, subsequently consulted a medical team at Duke University Medical Center. The Duke team determined that Kaiser's diagnosis was erroneous and recommended a different treatment plan. Michael received treatment at Duke that was ultimately successful. Kaiser denied Michael's request for coverage. Michael and Lacey sued Kaiser for, among other things, breach of contract and medical malpractice. Kaiser filed a motion to compel arbitration, arguing that a group agreement entered into Kaiser and the EUTF was applicable to Michael when he signed the enrollment form. The group agreement contained an arbitration provision. The circuit court granted the motion to compel arbitration. The Supreme Court vacated the circuit court's orders, holding (1) the arbitration provision was unenforceable based on the lack of an underlying agreement between Kaiser and Michael to arbitrate; and (2) accordingly, Lacey was also not bound to arbitrate her claims in this case. View "Siopes v. Kaiser Found. Health Plan, Inc." on Justia Law
Tierney v. Sakai
Petitioner, an inmate, submitted a petition for a writ of mandamus seeking an order directing the Director of the Department of Public Safety (DPS) to approve dental treatment, teeth cleaning, a root canal, a cavity fix, cancer treatment, and treatment for concussion for brain trauma. The Supreme Court declined to grant the requested relief, as (1) Petitioner failed to demonstrate that DPS was purposefully ignoring or failing to respond to his dental or medical needs; and (2) the documents attached to the petition demonstrated that DPS provided Petitioner medical and dental care within the purview of the State's services, apprised Petitioner of the option to seek outside care for services not covered by the State, and offered services for pain relief. View "Tierney v. Sakai " on Justia Law
Alohacare v. Dep’t of Human Servs.
Petitioner Alohacare bid for a health and human services contract under Haw. Rev. Stat. 103F but was denied the contract by Respondent, the Department of Human Services. Petitioner protested and later appealed. The lower courts dismissed Petitioner's appeal for lack of jurisdiction, finding that Petitioner was not entitled to judicial review. The Supreme Court vacated the judgment of the lower courts, holding (1) Petitioner may not appeal the denial of a contract award by Respondent under the procedures set forth in Haw. Rev. Stat. 103D that afford judicial review for bidders denied protests; (2) however, chapter 103F does not prohibit judicial review of the administrative denial of such matters, and review may be afforded under Haw. Rev. Stat. 632; (3) review and denial of a bidder's protest by Respondent as the purchasing agency and subsequent denial of a request for reconsideration by the chief procurement officer housed in a different executive agency do not assuage separation of powers concerns because review is accomplished only in the executive branch of government; and (4) Petitioner was not denied due process or equal protection by chapter 103F, inasmuch as judicial review may be obtained by way of a declaratory judgment action. Remanded. View "Alohacare v. Dep't of Human Servs." on Justia Law
Alaka’i Na Keiki, Inc. v. Matayoshi
State Department of Education (DOE) issued a request for proposals to provide health and human services under contracts pursuant to Haw. Rev. Stat. 103F. After the DOE rejected the proposal of Petitioner Alaka'i Na Keiki, Inc., Petitioner brought an action against the DOE. The circuit court granted summary judgment in favor of the DOE. The intermediate court of appeals affirmed, concluding that chapter 103F does not allow for judicial review. The Supreme Court vacated the judgment of the lower courts, holding that the DOE's decisions to reject such proposals were subject to judicial review. The Court then held (1) as construed, chapter 103F was not unconstitutional for violating the separation of powers doctrine; (2) Petitioner's request for a declaratory judgment was moot to the extent the subject contracts had been awarded and their terms expired; (3) Petitioner's claim for negligence by the DOE was barred under the State Tort Liability Act; and (4) Petitioner's claim for injunctive relief, premised on the DOE's alleged faulty administration of the contract process, was moot inasmuch as the Court interpreted such process in chapter 103F as subject to judicial review. Remanded. View "Alaka'i Na Keiki, Inc. v. Matayoshi " on Justia Law
Alohacare v. Ito
Alohacare, a health maintenance organization (HMO), submitted a proposal to the Department of Human Services to bid for a Quest Expanded Access contract to provide healthcare services for participants in the state's Medicaid program. The Department of Human Services awarded Quest contracts to United HealthCare Insurance (United) and WellCare Health Insurance (Ohana) but not to Alohacare. Alohacare petitioned the Insurance Commissioner of the Department of Commerce and Consumer Affairs for declaratory relief that the Quest contracts required the accident and health insurers to carry an HMO license. The Commissioner concluded that the license was not required to offer the Quest managed care product because the services required under the contracts were not services that could be provided only by an HMO. The circuit court affirmed. The Supreme Court affirmed, holding (1) AlohaCare had standing to appeal the Commissioner's decision; (2) both accident and health insurers and HMOs were authorized to offer the model of care required by the Quest contracts; and (3) this holding did not nullify the Health Maintenance Organization Act. View "Alohacare v. Ito" on Justia Law
Miller v. Hartford Life Ins. Co.
This lawsuit arose from an insurance contract between Plaintiff, who had cancer, and Defendants, two insurance companies. In May 2007, Plaintiff applied for long-term care benefits under her policy. Defendants found her eligible for benefits and paid her caregiver for services beginning in October 2007. Defendants provided coverage for Plaintiff for almost a year, then terminated her benefits on August 25, 2008. Nearly five months later, on January 23, 2009, Defendants reinstated her benefits retroactively. After Defendants terminated Plaintiff's benefits, she attempted suicide. On July 9, 2009, Plaintiff sued Defendants, alleging, inter alia, insurer bad faith and negligent and intentional infliction of emotional distress. The Supreme Court subsequently accepted a question certified to it by the district court and answered it by holding that if a first-party insurer commits bad faith, an insured need not prove the insured suffered economic or physical loss caused by the bad faith in order to recover emotional distress damages caused by the bad faith. View "Miller v. Hartford Life Ins. Co." on Justia Law