Justia Hawaii Supreme Court Opinion Summaries

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

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

Petitioner filed a workers’ compensation claim with the Director of Labor and Industrial Relations seeking compensation for the aggravation of his asthma resulting from his exposure to vog while working as a school teacher. The Director denied Petitioner’s claim, and the Labor and Industrial Relations Appeals Board (LIRAB) affirmed. The intermediate court of appeals (ICA) affirmed the LIRAB’s decision. The Supreme Court vacated the ICA’s judgment and the LIRAB’s decision, holding that Petitioner was entitled to compensation pursuant to Haw. Rev. Stat. 386-3(a), which provides that if an employee suffers an injury proximately caused by employment, the employee shall be paid compensation. Remanded to the Director for a determination of the amount of compensation to be awarded. View "Van Ness v. State, Dep’t of Educ." on Justia Law

Del Monte Fresh Produce Company decided to cease growing pineapples at its plantation on O'ahu. The company's subsidiary, Del Monte Fresh Produce (Hawaii), Inc, subsequently bargained with the International Longshore and Warehouse Union, Local 142, with regard to the effects of that decision on Del Monte employees in Hawaii. The Union believed the company was not negotiating in good faith and filed a complaint with the Hawai'i Labor Relations Board alleging that Del Monte had engaged in unfair labor practices. The Hawaii Labor Relations Board (HLRB) entered an order concluding that Del Monte failed to bargain in good faith. The circuit court and intermediate court of appeals affirmed. The Supreme Court affirmed, holding that the HLRB did not clearly err in finding Del Monte engaged in bad faith bargaining, because there was substantial evidence that the totality of Del Monte's conduct did not evince a present intention to find a basis for agreement and a sincere effort to reach common ground. View "Del Monte Fresh Produce (Haw.), Inc. v. Int'l Longshore & Warehouse Union, Local 142" on Justia Law

Employee was allegedly involved in a work-related accident on property owned by Corporation. Insurer was Employer's insurance carrier. While paying Employee's workers' compensation benefits, Insurer filed suit against Corporation, asserting its right of subrogation. After the statute of limitations period had elapsed, Employee sought to intervene in Insurer's suit, and the circuit court granted Employee's request. Corporation subsequently moved for summary judgment on the ground that Haw. Rev. Stat. 386-8, which governs the right of an employee to intervene in an employer's third party liability lawsuit under workers' compensation law, did not allow an employee to intervene after the statute of limitations had expired. The circuit court granted Corporation's motion and entered judgment against Employee. The Supreme Court vacated the circuit court's judgment and remanded, holding that Employee could intervene in Insurer's action against Corporation because section 386-8 did not limit Employee's right to intervene in Insurer's timely filed lawsuit. View "First Ins. Co. of Haw., Ltd. v. A&B Props., Inc." on Justia Law

Governor Linda Lingle filed an executive order unilaterally imposing three-day-per-month furloughs for all state employees and reducing the Department of Education's and University of Hawaii's spending accordingly. The Hawaii State Teachers Association and United Public Workers (collectively, Plaintiffs) brought this action, asserting several causes of action and moving for a temporary restraining order. The circuit court granted in part Plaintiff's motion for a temporary injunction and held for Plaintiffs. The Supreme Court vacated the circuit court's judgment, holding (1) the dispute in this case ultimately related to a prohibited practice pursuant to Haw. Rev. Stat. 89; and (2) the circuit court erred by deciding statutory issues over which the Hawaii Labor Relations Board had exclusive jurisdiction. View "State Teachers Ass'n v. Abercrombie" on Justia Law