Justia Hawaii Supreme Court Opinion Summaries

Plaintiff, a ward at a youth correctional facility, filed a complaint against Scott Rosete, a youth correctional officer, in his individual and official capacities, the State, and other defendants, alleging assault and battery as against Rosete, among other claims. Rosete was found liable for sexual assault. The circuit court granted in part Rosete’s, in his individual capacity, motion for a new trial based on an irreconcilable conflict in the jury’s answers to special verdict questions. The Supreme Court affirmed the circuit court’s order granting Rosete a new trial, holding (1) the issues on retrial should be limited to the measure of general and special damages each defendant should pay, with the jury properly instructed on when each defendant can be held liable in his individual, versus official, capacity; and (2) Haw. Rev. Stat. 662-10 did not operate to bar contemporaneous judgments against both the State and Rosete in his individual capacity. View "Costales v. Rosete" 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

Petitioners filed a complaint against Respondents for violations of the Uniform Fraudulent Transfers Act (UFTA). The circuit court dismissed the action without discussing Respondents’ argument that Petitioners’ claim was untimely. Petitioners appealed. Respondents cross-appealed, asserting that Petitioners’ UFTA claim was time-barred. The intermediate court of appeals (ICA) ruled on the statute of limitations issue raised in the cross-appeal and concluded that Petitioners’ UFTA claim should have been dismissed as untimely, holding that the one-year limitations period begins when a transfer, rather than its fraudulent nature, is discovered. The Supreme Court vacated the judgment of the ICA, holding (1) the one-year limitations period under UFTA begins on the date a transfer commences when a plaintiff discovers or could reasonably have discovered a transfer’s fraudulent nature; and (2) the ICA erred in its ruling on the statute of limitations issue and should have decided the merits of the claim raised in Petitioner’s appeal. Remanded. View "Schmidt v. HSC, Inc." on Justia Law

Because of a property dispute, Petitioner filed a complaint against Respondents. The trial court granted Respondents judgment as a matter of law (JMOL) on Petitioner’s breach of fiduciary duty claim. The jury then rendered a special verdict against Petitioner on the remainder of Petitioner's claims. After the verdict was read into the record and the jury was discharged, the trial court recalled the jury. The jurors were polled, and one juror responded that the verdict as read did not reflect his verdict. The intermediate court of appeals (ICA) sustained the verdict, holding that a jury cannot be recalled following an order discharging the jury. The Supreme Court affirmed in part and vacated in part the judgment of the ICA, holding (1) a court may recall a jury following a formal discharge if the jury is subject to the control of the court; (2) the jurors’ statements that they misunderstood the legal effect of their answers to a special verdict question did not provide a basis for overturning the jury’s verdict in favor of Respondents; and (3) JMOL was correctly granted on Petitioner’s breach of fiduciary duty claim. View "Lahaina Fashions, Inc. v. Bank of Hawai’i" on Justia Law

The County of Kauai Planning Commission approved a subdivision application for a Trust's development of land in Koloa, Kauai. During the Commission's consideration of the application, the parties assumed that a historic road (Road) that the Trust needed to breach to provide access into the subdivision belonged to the County of Kauai. Plaintiff filed a civil complaint alleging several claims against Defendants, including breaches of the public trust. Plaintiff subsequently amended his complaint because he discovered that the road belonged to the State and not the County and asserted two additional claims against the Trust for allegedly breaching the Road. The circuit court dismissed the claims, concluding (1) because the State had not given its approval to breach the Road, the issues raised in Plaintiff's complaint were not ripe; and (2) even if Plaintiff had claims that were ripe and severable, the court had the discretion to dismiss the claims in the interest of judicial economy. The Supreme Court vacated the circuit court's final judgment, holding (1) all of Plaintiff's claims were ripe for adjudication; and (2) the circuit court erred in dismissing claims on the basis of judicial economy. Remanded. View "Blake v. County of Kauai Planning Comm'n" on Justia Law

Respondents, the City and County of Honolulu and certain individuals, banned Petitioners, two stagehands, from working at certain City-owned facilities based on Petitioners' involvement in a charitable concert featuring the City's mayor. After a jury-waived trial, the circuit court entered judgment in favor of Respondents on all claims, including Petitioners' claims that the ban was unconstitutional. The intermediate court of appeals affirmed. The Supreme Court vacated the lower courts' judgments, holding that the City's ban interfered with Petitioners' liberty interests under the Hawaii Constitution and that the City failed to satisfy due process by instituting the ban without giving Petitioners notice and an opportunity to be heard. Remanded. View "Minton v. Quintal" on Justia Law

Plaintiffs, individually and as personal representatives of Makamae Ah Mook Sang's estate, filed a negligence action against defendants after Makamae died of acute alcohol intoxication after attending a party at defendants' home. At issue was whether a social host who invited a minor onto his or her property and then directly served to the minor owed a duty of care to prevent foreseeable injuries resulting from consumption of the alcohol, or to render or summon aid if injuries have occurred, while the minor remained on the property as a guest. The court held that a social host in the circumstances presented in this case owed a duty of care to a minor when the host has placed the minor in a position of peril and did not act to prevent foreseeable harm to the minor that could thereby result, and when the host did not act to aid the minor in the event that harm had occurred. Accordingly, the court vacated the circuit court's order and judgment, remanding for further proceedings. View "Sang v. Clark" on Justia Law

Jasmine Fry, a twenty-two-year-old woman, died after entering into and becoming trapped in an exhaust duct above the food court in the Ala Moana Center (Ala Moana). Fry entered the duct by way of the building's rooftop. Fry's parents (Plaintiffs) sued Ala Moana, alleging various tort claims. The circuit court entered summary judgment in favor of Ala Moana on all claims. The intermediate court of appeals affirmed, concluding that Ala Moana did not owe Fry a legal duty under any theory of liability. The Supreme Court vacated in part and affirmed in part, holding (1) summary judgment was properly granted on Plaintiffs' general premises liability claims because Ala Moana owed no duty to a person not reasonably anticipated to be on the rooftop and because Fry's entry into the duct was not reasonably foreseeable; (2) genuine issues of fact existed as to whether Ala Moana breached its duty under the Restatement (Second) of Torts 338; and (3) genuine issues of fact existed as to whether Fry was a member of the public who entered the center in response to Ala Moana's invitation and, if so, whether Ala Moana breached its duties under the Restatement (Second) of Torts 314A(3). Remanded. View "Winfrey v. GGP Ala Moana LLC" on Justia Law

Plaintiffs brought a negligence action against the City for damages arising from an accident in which William Kobashigawa was truck and killed while crossing a mid-block crosswalk. The jury returned a verdict in favor of the City, finding the City was not negligent. The intermediate court of appeals (ICA) vacated the jury verdict and remanded for a new trial, concluding that the circuit court plainly erred in giving a cautionary instruction that permitted the jury to consider evidence of Plaintiffs' motive in filing suit and in allowing the City to comment on that motive in its closing argument. The Supreme Court affirmed as modified, holding (1) the ICA correctly found that the circuit court's cautionary instruction regarding motive was a prejudicially erroneous statement of the law; but (2) the ICA incorrectly found that Plaintiffs failed to preserve their objections to the admission of irrelevant evidence concerning their motive in filing suit and that such failure required it to resort to plain error review. View "Kobashigawa v. Silva" on Justia Law

Appellant, a medical doctor, challenged the partial denial of personal injury protection benefits after treating a patient insured by Appellee. While Appellant's request for an administrative hearing was pending in the Insurance Division of the State Department of Commerce and Consumer Affairs, the patient's available benefits under her policy were exhausted on account of payments to Appellant and other medical providers. Because of the exhaustion, the Insurance Division dismissed Appellant's claim. The circuit court and intermediate court of appeals (ICA) affirmed. The circuit court also denied Appellant's request for attorney's fees and costs under Haw. Rev. Stat. 431:10C-211(a), which allows fees and costs to be awarded even when a party does not prevail on its claim for benefits, finding Appellant's pursuit of the benefits to be unreasonable. The ICA affirmed. Appellant appealed the denial of attorney's fees. The Supreme Court vacated the ICA's judgment and the circuit court's final judgment, holding that the circuit court and ICA erred in concluding that Appellant's claim was unreasonable due to exhaustion of benefits where Plaintiff had made his claim prior to that exhaustion. Remanded. View "Jou v. Schmidt" on Justia Law