Justia Hawaii Supreme Court Opinion Summaries

In this case, the defendants executed a promissory note and mortgage in 2008, which were eventually assigned to Wells Fargo Bank, N.A. In 2015, Wells Fargo initiated a foreclosure action against the defendants, alleging default on the mortgage. During the pendency of the proceedings, Wells Fargo assigned the mortgage to UMB Bank, National Association, which was substituted as the plaintiff. A central issue in the case was whether Wells Fargo possessed the original promissory note at the time the foreclosure complaint was filed, a requirement for standing to foreclose.The Circuit Court of the First Circuit first denied Wells Fargo’s summary judgment motion, finding insufficient admissible evidence of note possession at the time the lawsuit commenced. Later, UMB as successor plaintiff submitted additional declarations and business records in support of a renewed summary judgment motion. The circuit court found these sufficient and ruled in favor of UMB on standing. Shortly before trial, the parties entered into a stipulation regarding certain facts, including that Wells Fargo held the note before the action began and was the current holder, but the stipulation did not specify continuous possession or possession specifically on the complaint’s filing date. The circuit court relied on both the earlier summary judgment ruling and the stipulation, ultimately issuing a foreclosure decree for UMB. On appeal, the Intermediate Court of Appeals affirmed, emphasizing enforcement of the stipulation.The Supreme Court of the State of Hawaiʻi reviewed the case and held that there remained a genuine issue of material fact as to whether Wells Fargo possessed the note when the complaint was filed. The court found the evidence submitted by UMB ambiguous and the stipulation insufficiently specific to establish standing. The Supreme Court vacated the judgments of the lower courts and remanded the case for further proceedings to resolve this factual issue. View "UMB Bank, N.A. v. Tupulua" on Justia Law

A nonprofit environmental organization challenged the Maui Planning Commission’s amended rules, which governed development in Maui’s Special Management Area (SMA), a protected coastal zone. The amendments created fifteen categorical exemptions from environmental assessment, some with monetary thresholds and some based on landowner declarations. The rules also allowed continuation, repair, or renovation of previously approved developments without new environmental review, and replaced the requirement for a final environmental assessment (EA) with a draft EA for permit applications.After the rules were enacted, the nonprofit filed a complaint in the Circuit Court of the Second Circuit, arguing that the commission’s rules unlawfully bypassed the Coastal Zone Management Act’s (CZMA) required assessment process, shifting the duty to regulated parties and undermining statutory and constitutional protections. The commission responded that its exemptions were within its rulemaking power, claiming they excluded non-development activities from the CZMA process. The circuit court granted summary judgment for the nonprofit, invalidating the relevant rule sections and restoring the final EA requirement.The Maui Planning Commission and County of Maui appealed. The Supreme Court of the State of Hawaiʻi affirmed the circuit court’s decision. The court held that the commission’s rules exceeded its statutory authority by creating categorical exemptions from the CZMA’s assessment process and unlawfully delegating assessment duties to private parties. The court also found that replacing the final EA with a draft EA undermined required environmental safeguards. The Supreme Court clarified that counties may streamline permitting but cannot eliminate the statutory assessment process or delegate it to applicants. The court affirmed the invalidation of the amended rules. View "Maui Tomorrow Foundation v. Maui Planning Commission" on Justia Law

The case involved a dispute over real property on Maui. The plaintiffs had purchased a large tract of land at a foreclosure auction, which included two small “Piena Parcels” originally awarded to an individual named Piena in the mid-1800s. The defendant entered the property, remained there without permission, altered the land, and asserted she was the rightful heir to the Piena Parcels. The plaintiffs sued for trespass and nuisance, seeking damages, declaratory and injunctive relief.The Circuit Court of the Second Circuit first granted the plaintiffs' motion to compel discovery and awarded them attorney fees as a sanction against the defendant for inadequate discovery responses. Later, the court granted summary judgment to the plaintiffs on their claims, including as to the Piena Parcels, and issued a writ of possession, ordering the defendant to vacate. The court also awarded the plaintiffs substantial attorney fees and costs as prevailing parties. The defendant appealed these rulings.The Intermediate Court of Appeals upheld the discovery sanction and the summary judgment but vacated the prevailing party fee award, finding it excessive. The defendant then sought further review.The Supreme Court of the State of Hawai‘i affirmed the discovery sanction, concluding the circuit court did not abuse its discretion in awarding attorney fees against the defendant. However, the Supreme Court vacated the summary judgment as to the Piena Parcels. It held that a genuine issue of material fact existed regarding the plaintiffs’ ownership of those parcels, as their evidence did not adequately establish a continuous chain of title from Piena to themselves. Thus, the court remanded the case for further proceedings on the ownership of the Piena Parcels. View "ATC Makena N Golf LLC v. Kaiama." on Justia Law

A dispute arose regarding the possession of four homes on homestead land in Hau‘ula, which is subject to a 999-year lease originally granted to Mary Kapuna Takemoto in 1938. The petitioners, descendants of the original lessee, had lived on the property for decades and claimed a right to remain as lineal heirs. The respondent, acting as the personal representative of the estate of another descendant, occupied one of the homes and sought to eject the petitioners from the remaining three, arguing he was entitled to possession.The District Court of the First Circuit denied the petitioners’ motion to dismiss, which argued that the court lacked subject matter jurisdiction due to real property title issues. The court then granted summary judgment for the respondent, issuing a judgment for possession and writ of possession against the petitioners, but reserving the question of damages. The petitioners’ subsequent motion to stay enforcement was denied. They appealed to the Intermediate Court of Appeals (ICA), challenging both the jurisdictional ruling and the summary judgment. The ICA denied their motion to stay, finding insufficient grounds to set a reduced bond or allow alternative security.The Supreme Court of the State of Hawai‘i reviewed the ICA’s denial via a petition for writ of mandamus. The court held that the ICA erred by failing to consider relevant factors for a stay pending appeal, as set forth in Kelepolo v. Fernandez, including the public interest, financial burden, alternative security, and discouragement of appeals. The Supreme Court granted the writ, staying enforcement of the judgment and allowing the petitioners to remain on the property so long as they continue to pay their share of expenses during the appeal. The court made clear that any damages for delay could be pursued by the respondent if he prevails on appeal. View "Preston v. Hiraoka" on Justia Law

A group of individuals who own or reside in the Makila Plantation neighborhood in Launiupoko, Maui, sought to intervene in a public hearing concerning a special use permit (SUP) application submitted by Goodfellow Bros., LLC. Goodfellow had applied for the SUP to operate a temporary rock-crushing facility on nearby agricultural land, which would process rocks for use in local construction projects. The project had been the subject of community outreach and was publicized through required legal notices and additional informational meetings. The Appellants were not entitled to direct notice as they did not live within 500 feet of the project, but they became aware of the hearing through their homeowners association and submitted written testimony expressing concerns about the project’s impact.Despite knowing about the project and the public hearing, Appellants filed their petition to intervene less than 24 hours before the scheduled hearing, missing the deadline set by the Maui Planning Commission’s (MPC) rules. At the August 8, 2023 hearing, the MPC considered whether there was “good cause” for the untimely filing of the petition. After discussion and testimony from both sides, the MPC found that Appellants had sufficient notice and opportunity to file earlier but did not show good cause for their delay. The MPC voted unanimously to deny the petition to intervene and subsequently approved the SUP application with amended conditions, including prohibiting rock-crushing on the property.The Supreme Court of the State of Hawaiʻi reviewed the matter on appeal. The court held that the MPC did not abuse its discretion in denying the untimely petition because Appellants failed to demonstrate good cause for their late filing. The court also found no evidence that the MPC’s decision was based on Appellants’ residency status, nor was the MPC required to hold a contested case hearing on the untimely petition. The court affirmed the MPC’s decision. View "Gutschmidt v. Maui Planning Commission" on Justia Law

A purchaser entered into a condominium sales contract with a developer, which incorporated an escrow agreement between the developer and an escrow company. The purchaser was not a signatory to the escrow agreement, nor was the escrow company a party to the sales contract. After the purchaser defaulted on the sales contract by failing to make the required closing payment, the developer sent notices of default and contract termination, copying the escrow company. The termination notices included instructions regarding the disposition of the purchaser’s escrowed deposits—one letter indicated the developer would retain fifteen percent of the purchase price as liquidated damages, while a later letter stated the intent to retain the entire deposit. The escrow company subsequently released the entire escrow balance to the developer.Prior to this appeal, the Circuit Court of the First Circuit granted summary judgment in favor of the escrow company on the purchaser’s claims for breach of contract and breach of fiduciary duty, finding that the escrow company had complied with the escrow agreement as incorporated into the sales contract. The Intermediate Court of Appeals (ICA) affirmed denial of the purchaser’s partial summary judgment motion but vacated summary judgment for the escrow company on the breach of contract and fiduciary duty claims. The ICA found a genuine issue of material fact as to whether the escrow company breached its duties by releasing all funds after receiving what it characterized as conflicting instructions from the developer.The Supreme Court of the State of Hawai‘i held that the escrow company strictly complied with the terms of the escrow agreement, which, upon default and proper written notice, required release of all escrowed funds to the developer. The court concluded there was no genuine issue of material fact regarding breach of contract or fiduciary duty. The court vacated the ICA’s judgment regarding those claims and affirmed summary judgment for the escrow company, remanding only the issue of attorney fees to the ICA. View "Yamaguchi v. Title Guaranty Escrow Services, Inc." on Justia Law

The dispute stems from a series of lawsuits initiated by a borrower after a nonjudicial foreclosure was attempted on a Maui property he purchased in 2003. Following his default on the mortgage in 2008, the property was sold in a nonjudicial foreclosure in 2010 and title transferred to a bank. The bank, through its attorneys, sought to evict the borrower and later filed a judicial foreclosure counterclaim after the borrower challenged the foreclosure's validity. The borrower remained in possession of the property throughout, and subsequent litigation centered on the conduct of both the lender and its attorneys.After an initial summary judgment against the borrower in his wrongful foreclosure suit, the Hawai‘i Intermediate Court of Appeals (ICA) vacated and remanded for further proceedings. On remand, the parties settled most claims except those against certain attorneys. Separately, the borrower filed new claims against the bank’s law firm and its attorneys, alleging fraud, unfair and deceptive acts, wrongful foreclosure, and other torts related to their legal filings and conduct during the foreclosure process. The Circuit Court of the Second Circuit granted judgment on the pleadings in favor of the attorneys and declared the borrower a vexatious litigant due to a pattern of abusive litigation.On appeal, the ICA affirmed most of the circuit court’s rulings but reinstated the borrower’s claim alleging fraud on the court. The Supreme Court of the State of Hawai‘i held that the ICA erred by reinstating this claim, reasoning that even if the borrower’s allegations were true, they did not meet the high threshold required for an independent action for fraud on the court. The Supreme Court affirmed the circuit court’s dismissal of all claims against the attorneys and the vexatious litigant order, and vacated the ICA’s ruling to the extent it had revived the fraud on the court claim. View "Greenspon v. Deutsche Bank National Trust Company" on Justia Law

The plaintiffs in this case are trustees who own a property in Kīhei, Maui, which they use as a vacation home for personal use. In 2021, Maui County reclassified their property as a “short-term rental” based solely on zoning, not actual use, resulting in a higher property tax rate. The plaintiffs paid the assessed taxes but did not utilize the administrative appeals process available through the Maui County Board of Review. Instead, they filed a class action in the Circuit Court of the Second Circuit, seeking a refund and alleging that the County’s collection of the higher taxes was unconstitutional, violated due process, and resulted in unjust enrichment.The Circuit Court of the Second Circuit granted the County’s motion to dismiss, finding it lacked subject matter jurisdiction. The court determined that under Hawai‘i Revised Statutes chapter 232 and Maui County Code chapter 3.48, the proper procedure for contesting real property tax assessments—including constitutional challenges—requires first appealing to the County Board of Review and, if necessary, then to the Tax Appeal Court. Because the plaintiffs bypassed these required steps and missed the statutory deadline to appeal, the court dismissed the case with prejudice.On appeal, the Supreme Court of the State of Hawai‘i affirmed the circuit court’s dismissal. The Supreme Court held that the Tax Appeal Court has exclusive jurisdiction over appeals regarding real property tax assessments, including those raising constitutional issues, and found that the plaintiffs’ claims were time-barred due to their failure to timely pursue the established administrative remedies. As a result, the Supreme Court affirmed the circuit court’s judgment dismissing the plaintiffs’ claims for lack of subject matter jurisdiction. View "Piezko v. County of Maui" on Justia Law

The dispute centers on the extension of a grading and grubbing permit issued by the Director of the Department of Public Works, County of Maui, to Maui Lani Partners for excavation work at a residential development site containing ancestral Hawaiian burial sites. In March 2018, an unincorporated association and its members challenged the validity of the permit extension, alleging violations of state and county laws requiring consultation with the State Historic Preservation Division and arguing that the Director exceeded his authority in granting the extension without good cause.The Circuit Court of the Second Circuit granted motions to dismiss the complaint on all counts without prejudice, finding no regulatory or statutory authority requiring consultation with the State Historic Preservation Division for permit extensions and that the Director acted within his discretionary authority. The court denied the plaintiffs’ motion for summary judgment and later denied their HRCP Rule 60(b)(6) motion for reconsideration, concluding that the plaintiffs had not presented new law or argument. The plaintiffs appealed to the Intermediate Court of Appeals (ICA), which affirmed the circuit court’s denial of costs and the motion for reconsideration but held that the notice of appeal was untimely because the Rule 60(b) motion was not filed within ten days of judgment and thus did not toll the appeal deadline.The Supreme Court of Hawaiʻi reviewed the case and held that a motion for reconsideration filed under HRCP Rule 60(b) is a “tolling motion” under HRAP Rule 4(a)(3) if filed within a reasonable time and before the appeal deadline, thereby extending the time to file a notice of appeal. The court also held that the ICA did not err in affirming the circuit court’s denial of the Rule 60(b)(6) motion for reconsideration. The Supreme Court vacated the ICA’s judgment in part and remanded for further proceedings. View "Kakanilua v. Director of the Department of Public Works" on Justia Law

The dispute centers on an option agreement for the lease of approximately 598 acres of land owned by one party and sought by another for use in a biomass power plant operation. The option agreement granted the potential lessee an irrevocable one-year option to lease the property, with a proposed lease attached that included some terms, such as base rent amounts, but omitted others, including the effective date and certain pricing details for a percentage rent provision. After the lessee attempted to exercise the option, the lessor sent a lease largely in the form of the proposed lease, but with key terms still blank. The lessee never signed this lease, and the parties disagreed about whether a binding lease had been formed.The owner filed suit in the Circuit Court of the Fifth Circuit, seeking breach of contract and specific performance. After a bench trial, the circuit court found that the proposed lease was missing essential terms and that the parties did not intend to be bound by it when executing the option agreement. The court granted the lessee’s motion for directed verdict, awarded attorneys’ fees and costs, and entered final judgment. On appeal, the Intermediate Court of Appeals (ICA) vacated the circuit court’s judgment, holding that the proposed lease was sufficiently definite and enforceable, and that the parties were bound by its terms upon exercise of the option.The Supreme Court of Hawai‘i reviewed the ICA’s decision. It held that the proposed lease lacked sufficiently definite terms, specifically regarding the effective date and percentage rent provision, and that the parties did not intend to be bound by the proposed lease without further negotiation. The Supreme Court reversed the ICA’s judgment and affirmed the circuit court’s directed verdict, fee award, and final judgment in favor of the lessee. View "Moloaa Farms LLC v. Green Energy Team LLC" on Justia Law