Justia Hawaii Supreme Court Opinion Summaries

The case revolves around Honoipu Hideaway, LLC's (Honoipu) appeal of the Land Use Commission’s (LUC) order denying its petition for a declaratory order to change the boundary location between the conservation and agricultural districts on a district boundary map. The appeal was initially filed with the Circuit Court of the Third Circuit. However, following a decision in another case, In re Kanahele, it was determined that appeals of LUC declaratory orders should have been filed with the Supreme Court of Hawai‘i in the first instance. This led to a question of whether the circuit court had the authority to transfer the appeal to the Supreme Court of Hawai‘i.The Circuit Court of the Third Circuit had initially accepted the appeal. However, following the decision in In re Kanahele, it was determined that the Supreme Court of Hawai‘i was the correct court for such appeals. This led to a dispute between Honoipu and the LUC, with Honoipu arguing for the transfer of the case to the Supreme Court, and the LUC arguing for dismissal due to lack of jurisdiction.The Supreme Court of Hawai‘i held that the Circuit Court of the Third Circuit had both inherent and statutory authority to transfer the appeal to the Supreme Court. The court reasoned that the power to "do such other acts and take such other steps as may be necessary to carry into full effect the powers which are or shall be given to them by law or for the promotion of justice" gave the circuit court the power to correct a jurisdictional mistake that was no party’s or court’s fault. The court also noted that transferring the case would further the judiciary’s policy of permitting litigants to appeal and hear the case on its merits. View "Honoipu Hideaway, LLC v. State" on Justia Law

The case involves plaintiffs Ronnie and Sharon Llanes and Michael and Lauren Codie (collectively, Borrowers) who purchased homes with mortgages from Bank of America, N.A. (Lender). After the Borrowers defaulted on their mortgages, the properties were foreclosed upon and sold in nonjudicial foreclosure sales. The Borrowers then sued the Lender for wrongful foreclosure, alleging that the Lender's foreclosures did not comply with Hawai‘i Revised Statutes (HRS) § 667-5 (2008) (since repealed).The case was initially heard in the Circuit Court of the Third Circuit, where the Lender moved for summary judgment, arguing that the Borrowers did not prove damages. The circuit court denied the motion due to factual disputes and lack of clarity in existing law. However, after the Supreme Court of Hawai‘i issued its decision in Lima v. Deutsche Bank Nat’l Tr. Co., the Lender renewed its summary judgment motion, arguing that under Lima, the Borrowers’ claims failed as a matter of law because they did not provide evidence of damages that accounted for their pre-foreclosure mortgage debts. The circuit court granted the Lender's renewed motion for summary judgment, concluding that the Borrowers had not proven their damages after accounting for their debts under Lima.On appeal to the Supreme Court of the State of Hawai‘i, the Borrowers argued that the circuit court erred by concluding that they bore the burden of proving their damages and did not meet that burden. The Supreme Court affirmed the circuit court's decision, holding that outstanding debt may not be counted as damages in wrongful foreclosure cases. The court concluded that the Borrowers did not prove the damages element of their wrongful foreclosure claims, and therefore, the circuit court properly granted summary judgment to the Lender. View "Llanes v. Bank of America, N.A." on Justia Law

This case involves a dispute over the Mauna Kea Access Road (MKAR) in Hawaii, which partially lies on Hawaiian home lands. The plaintiffs, who are Native Hawaiian beneficiaries of the Hawaiian home lands trust, sued the State of Hawaii and several of its departments, alleging that they breached their trust duties by allowing the State to use MKAR lands without payment since the 1970s. They also argued that the State's attempt to designate MKAR as a state highway in 2018 was ineffective as a matter of law.The lower court granted summary judgment in favor of the defendants, based on Act 14 of 1995, which was intended to resolve all controversies relating to the Hawaiian home lands trust that arose between 1959 and 1988. The defendants argued that Act 14 remedied the uncompensated use of the Hawaiian home lands underlying the MKAR and made enforcement of a land exchange the exclusive remedy for the plaintiffs.The Supreme Court of the State of Hawaii disagreed with the lower court's ruling. The Supreme Court held that Act 14 of 1995 does not preclude the plaintiffs' claims, that the portion of the MKAR going through Department of Hawaiian Home Lands (DHHL) lands is not a state highway because legal requirements for such a designation were not satisfied, and that the State breached its constitutional and fiduciary obligation to faithfully carry out the Hawaiian Homes Commission Act, 1920. The Supreme Court vacated the lower court's judgment and remanded the case for further proceedings. View "Kanahele v. State" on Justia Law

This case involves a dispute over property ownership between Rosalinda Ganir Saplan and Recto Ramos Saplan (the Saplans) and U.S. Bank. After the Saplans defaulted on their mortgage, U.S. Bank foreclosed on the property and filed an ejectment action against the Saplans in 2011. However, U.S. Bank failed to schedule a required pretrial conference, leading the circuit court to dismiss the ejectment action for want of prosecution. The Saplans then filed a quiet title action in 2015, arguing that the dismissal of the 2011 action had quieted title in their favor. U.S. Bank moved for summary judgment, arguing that the Saplans had not submitted any evidence in support of their claim of title. The circuit court granted the motion.The Intermediate Court of Appeals (ICA) held that the 2011 dismissal was on the merits for the purposes of claim preclusion, but it did not preclude U.S. Bank’s later action because the parties across these lawsuits were different. The ICA also held that summary judgment was improperly granted because U.S. Bank had not provided evidence that its foreclosure sale was fair, reasonably diligent, and in good faith, and the price was adequate.U.S. Bank appealed to the Supreme Court of the State of Hawai‘i, arguing that the ICA erred in holding that the 2011 dismissal was on the merits for the purposes of claim preclusion and that U.S. Bank had not met its burden of showing there were no genuine issues of material fact for trial. The Supreme Court held that without a final judgment, there cannot be claim preclusion. Here, there was no final judgment, so there can be no claim preclusion against U.S. Bank. The court also held that the ICA incorrectly applied the summary judgment standard when it held that U.S. Bank had not met its burden. Because this is the Saplans’ quiet title action, the Saplans have the burden of proof on the issue of property ownership. The court vacated the ICA’s judgment and affirmed the circuit court’s judgment. View "Saplan v. U.S. Bank" on Justia Law

The case involves Juan Angel Rubalcaba, a homeowner, who filed a wrongful foreclosure lawsuit against the Association of Apartment Owners of Makakilo Cliffs. The central issue was whether the mortgage debt of the homeowner to a third-party lender, which was discharged by the third-party lender's subsequent foreclosure, should be considered in determining the plaintiff's damages.The Circuit Court of the First Circuit sought guidance on this issue and forwarded a reserved question to the Supreme Court of the State of Hawai'i. The Supreme Court accepted the question, indicating that it would provide an answer through a related case, Wong v. Ass'n of Apartment Owners of Harbor Square, which was then pending before the court.The Supreme Court of the State of Hawai'i, after deciding the Wong case, provided guidance on how a plaintiff may calculate damages in a lawsuit against a condominium association for wrongful foreclosure. The court then remanded the case back to the Circuit Court of the First Circuit for further proceedings consistent with the Wong decision. The court did not provide a specific ruling on the reserved question but indicated that the lower court should follow the precedent set in the Wong case. View "Rubalcaba v. Association of Apartment Owners of Makakilo Cliffs " on Justia Law

The Supreme Court of the State of Hawaii addressed the calculation of damages in cases where a condominium association wrongfully forecloses on a unit owner. Stephen Wong, the plaintiff, had bought a condo in the Harbor Square complex, financing his purchase with a mortgage. He fell behind on his association assessments, and the Association of Apartment Owners (AOAO) of Harbor Square non-judicially foreclosed under Hawaiʻi Revised Statutes (HRS) Chapter 667. The foreclosure exceeded the AOAO’s statutory authority, leading Wong to sue for wrongful foreclosure. The court held that damages in such a case are the plaintiff's positive equity in the property, if any, plus lost use arising from the wrongful foreclosure, minus assessments owed to the AOAO. If the plaintiff was "underwater" on their mortgage (owing more than the home's fair market value), they could still potentially pursue a claim if the value of their wrongly taken use exceeds what they owe the AOAO in assessments. In Wong's case, he failed to establish lost use value, leading the court to affirm the lower court's grant of summary judgment to the AOAO. View "Wong v. Association of Apartment Owners of Harbor Square" on Justia Law

This case involves a dispute between the City and County of Honolulu, acting through the Honolulu Authority for Rapid Transportation (HART), and Victoria Ward, Limited, over the amount of just compensation to be paid for two acres of easements on property previously owned by Victoria Ward. The easements were obtained by HART for the construction of a fixed rail system and a proposed Kaka‘ako Station. The Supreme Court of the State of Hawai‘i ruled that the circuit court had erred in granting summary judgment on many of the issues in the case. The supreme court ruled that the circuit court had incorrectly used summary judgment to resolve disputed factual issues including whether Victoria Ward was estopped from seeking severance damages, whether Victoria Ward's claims relating to a "lost tower" were too speculative, and whether Victoria Ward was precluded from seeking severance damages for impacts to non-taken properties. The supreme court affirmed the circuit court’s grant of summary judgment on some issues, but vacated others and remanded the case back to the circuit court for further proceedings. The supreme court affirmed the circuit court's pause of the accrual of "blight of summons" interest during the pendency of the appeal. View "HART v. Ward " on Justia Law

The Supreme Court denied Petitioner's petition for a writ of mandamus challenging the final approval of the settlement in the underlying class action against the State, holding that Petitioner had no right to compensation.In 1920, the federal government pledged land to native Hawaiian beneficiaries, and while Hawai'i held the homestead land in trust it breached its fiduciary duties. In the underlying class action, trust beneficiaries successfully sued the State for breach of its trustee responsibilities, and the State settled. The Supreme Court accepted a petition for a writ of mandamus, an appeal challenging final approval of the case's settlement, and held (1) because Petitioner was born beyond the statutory period to receive a payout from the settlement he had no right to compensation; and (2) because this decision ended Petitioner's appeal, the appeal before the intermediate court of appeals was moot. View "Rivera v. Honorable Cataldo" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) ruling that the circuit court did not err in ordering an appointed commissioner to take possession and collect rents and during the period between summary judgment and confirmation of sale in this foreclosure case.The Association of Apartment Owners of Elima Lani Condominiums (AOAO) foreclosed on the previous owners of a condominium based on delinquent assessments and then PHH Mortgage Corporation, the mortgage lender, foreclosed on AOAO. AOAO appealed, arguing that the circuit court erred when it ordered that AOAO's possessory interest and right to collect rent from the property was extinguished upon entry of the foreclosure decree and erred when it vested the commissioner with legal and equitable title to the foreclosed property prior to the confirmation of sale. The ICA affirmed. The Supreme Court affirmed, holding that because the commissioner did not collect any rents, the ICA correctly held that the circuit court did not err in ordering the Commissioner to take possession and collect rents, and there were no rents to allocate under Haw. Rev. Stat. 514B-146(n). View "PHH Mortgage Corp. v. Patterson" on Justia Law

After recording a notice of default and intention to foreclose for unpaid assessments and costs, AOAO, a homeowners’ association, acquired the property by quitclaim deed in July 2015 after a non-judicial foreclosure sale. In September 2017, MTGLQ filed a complaint for foreclosure of the property and moved for summary judgment and an interlocutory decree of foreclosure, asking that a commissioner be appointed to take possession of the property, rent it out, and sell it. AOAO objected to MTGLQ’s request for possession and rents, arguing that Hawai͑i Revised Statutes 514B-146(n) referenced “any excess rental income received by the association” after a bank foreclosure, which meant the statute “clearly contemplated” that the association would continue in possession and collect rents. The court granted MTGLQ’s requests. In a January 2020 report, the Commissioner stated that he had conducted a public auction of the property and had collected $3,275.00 in rent for three months in 2019. The court confirmed the sale and awarded the rent to MTGLQ.The Supreme Court of Hawaii vacated the allocation of rent. Although AOAO’s right to rent and possession was terminated by the foreclosure judgment, section 514B-146(n) entitles it to the subsequent income to the extent that it has not already recouped its losses through rent previously collected. View "MTGLQ Investors, L.P. v. Association of Apartment Owners of Elima Lani Condominiums " on Justia Law