Justia Hawaii Supreme Court Opinion Summaries

Plaintiffs, Clarence Furuya and Lona Furuya, filed the underlying suit against Association of Apartment Owners of Pacific Monarch, Inc. (AOAO) raising issues related to their interests in an apartment unit located at the Pacific Monarch Condominium (Pacific Monarch) and 106 parking stalls appurtenant to the unit. The circuit court concluded that there was no enforceable contract between AOAO and the Furuyas for the purchase of the leased fee interests associated with the unit and the parking stalls. The Intermediate Court of Appeals (ICA) ultimately affirmed. The Supreme Court affirmed, holding (1) the Furuyas failed to demonstrate error in the circuit court’s decision; and (2) the circuit court did not err in rejecting the Furuyas’ related claims for injunctive relief, declaratory relief, and ultra vires act. View "Furuya v. Ass’n of Apartment Owners of Pacific Monarch, Inc." on Justia Law

Lloyd Anastasi loaned $2.4 million to a third party in exchange for a mortgage on a property supposedly owned by that third party. Fidelity Insurance Company insured that the third party had good title, but the warranty deed purporting to give title to the third party was forged. Anastasi was sued by the owners of the property, and Fidelity accepted tender of the claim under a reservation of rights. Anastasi later filed a bad faith and breach of contract claim against Fidelity, alleging that the lawsuit was used by Fidelity to delay paying him under the title insurance policy. The circuit court granted summary judgment in favor of Fidelity. The intermediate court of appeals (ICA) remanded in part and vacated in part. The Supreme Court (1) affirmed the ICA’s judgment insofar as it remanded to the circuit court an order allowing Fidelity to withhold certain documents that Anastasi requested during discovery under the attorney-client privilege and work product doctrine; and (2) vacated the ICA’s judgment insofar it it concluded that Anastasi failed to show any genuine issue of material fact that Fidelity acted in bad faith. View "Anastasi v. Fidelity Nat’l Title Ins. Co." on Justia Law

Buyers bought a commercial property from Seller. Buyers subsequently filed a complaint against Seller challenging the adequacy of Seller’s disclosures. The circuit court dismissed the action without prejudice to allow the parties to engage in mediation. Because of a dispute between the parties regarding mediation, the mortgage payments were briefly interrupted. Seller subsequently brought a foreclosure action against Buyers. Seller then held a nonjudicial public foreclosure auction at which she purchased the property by submitting the highest bid. After a trial on Buyers’ claims for nondisclosure and misrepresentation, the circuit court ordered judgment in favor of Seller. The court also ordered judgment in favor of Seller and against Buyers on Seller’s counterclaims for breach of the note and mortgage and ejectment. The intermediate court of appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding (1) Seller’s failure to disclose certain facts regarding the property’s sewer system was actionable under the nondisclosure and misrepresentation causes of action; and (2) Seller’s nonjudicial foreclosure of the property and ejectment of Buyers was wrongful. View "Santiago v. Tanaka" on Justia Law

Appellants, The Sierra Club and Senator Clayton Hee, challenged the Land Use Commission’s (LUC) reclassification of 1525 acres of Appellee D.R. Horton-Schuler Homes’ land from the agricultural state land use district to the urban state land use district. The circuit court affirmed the LUC’s findings of fact, conclusions of law, and decision and order. The Supreme Court affirmed, holding (1) the reclassification did not violate article XI, section 3 of the Hawai’i Constitution or Haw. Rev. Stat. 205-41 through -52; and (2) reliable, probative, and substantial evidence supported the LUC’s finding that the reclassification of the land at issue was consistent with the Hawai’i State Plan, would not substantially impair agricultural production, and was necessary for urban growth. View "Sierra Club v. D.R. Horton-Schuler Homes, LLC" on Justia Law

After Leigh Matsuyoshi fell behind on her mortgage payments, the property was auctioned off at a foreclosure sale. Thereafter, the mortgagee, who was also the purchaser of the foreclosed property, executed a quitclaim deed conveying the property to Kondaur Capital Corporation. Kondau filed a complaint for possession of the property against Matsuyoshi. The circuit court granted summary judgment for Kondaur. The Intermediate Court of Appeals (ICA) ultimately affirmed. Matsuyoshi appealed, citing Ulrich v. Security Investment Co. and arguing that the ICA misapplied the summary judgment standard by requiring her to present evidence when Kondaur had failed to present a prima facie case establishing that the sale of the property was valid. The Supreme Court vacated the judgments of the lower courts, holding (1) the duties set forth in Ulrich remain viable law and are applicable to non-judicial foreclosures of real property mortgages; (2) when a mortgagee acts as both the seller and the purchaser of property at a non-judicial foreclosure sale, that mortgagee or its quitclaim transferee bears the burden of proving compliance with the requirements of Ulrich; and (3) in this case, because Kondaur failed to satisfy its initial burden of showing that the foreclosure sale was conducted in compliance with the requirements of Ulrich, the burden never shifted to Matsuyoshi, and summary judgment was erroneously granted. View "Kondaur Capital Corp. v. Matsuyoshi" on Justia Law

This case involved a dispute between Plaintiff, Ka’upulehu Land LLC, and Defendants, heirs and assigns of Pahukula, et al., stemming from Plaintiff’s complaint to quiet title to certain property. Plaintiff, which obtained the property through paper title derived from a common grantor, claimed that neither it nor Defendants received valid title to the property because the common grantor had sold the property prior to his death. The circuit court entered summary judgment for Plaintiff, concluding that Plaintiff was entitled to the entire property by adverse possession. The Intermediate Court of Appeals (ICA) vacated the circuit court’s judgment, finding that there was a genuine issue of material fact with respect to the existence of a cotenancy. The Supreme Court vacated the judgments of the lower courts, holding (1) the evidence was not sufficient to establish that the common grantor was not vested with title to the property when he died, and therefore, title to the property descended in accordance with the law in effect at the time of the common grantor’s death to his heirs; and (2) Defendants and Plaintiff were cotenants because they both received their interests in the property through a series of conveyances stemming from the common grantor. View "Ka'upulehu Land LLC v. Heirs and Assigns of Pahukula " on Justia Law

At issue in this case was a coastal height setback requirement that limits development next to Waikiki’s shoreline. In 2010, Kyo-ya Hotels & Resorts LP submitted a land use permit to redevelop an existing hotel building with a twenty-six-story hotel and residential tower. The Director of the Department of Planning and Permitting granted partial approval of Kyo-ya’s variance application to allow the Project to encroach approximately seventy-four percent into the coastal height setback. Several entities (Petitioners) challenged the Director’s conclusion that Kyo-ya’s request for a variance from the coastal height Sstback met the requirements for issuance of a variance as set forth by the city charter. The Zoning Board of Appeals (ZBA) denied Petitioners’ appeal of the Director’s decision. The circuit court affirmed the ZBA order. The Supreme Court reversed, holding that Kyo-ya met none of the three requirements for issuance of a variance. View "Surfrider Found. v. Zoning Bd. of Appeal" on Justia Law

This case arose from a dispute over a flag lot parcel of land in Puko’o, located on the Island of Moloka’i, County of Maui, State of Hawaii. At issue before the Supreme Court was whether an order deciding a motion that was purportedly filed pursuant to Haw. R. Civ. P. 60(b) is appealable where the underlying ruling from which the party sought Rule 60(b) relief was not appealable. The Intermediate Court of Appeals (ICA) dismissed the appeal for lack of appellate jurisdiction, concluding that the order regarding the Rule 60(b) motion was not appealable because the circuit court had not entered a valid final judgment on the underlying claims at issue. The Supreme Court affirmed, holding that relief under Rule 60(b) requires an underlying judgment that comports with the principles of finality set forth in Jenkins v. Cades Schutte Fleming & Wright, and therefore, the ICA did not err in including that it lacked appellate jurisdiction to review the order regarding the Rule 60(b) motion. View "Bailey v. Duvauchelle" on Justia Law

Plaintiffs, individual condominium owners, entered into purchase agreements with the developer of a Maui condominium project. Homeowners received the condominium declaration, which contained an arbitration clause, and other documents governing the project along with their purchase agreements. When the condominium development began experiencing financial problems, Homeowners filed suit against Respondents, the development and management companies for the project. Respondents filed a motion to compel arbitration, which the circuit court summarily denied. The intermediate court of appeals (ICA) reversed, holding that a valid arbitration agreement existed, this dispute fell within the scope of that agreement, the arbitration terms were procedurally conscionable, and the arbitration clause was not an unenforceable contract of adhesion. The Supreme Court vacated the ICA’s judgment and affirmed the circuit court’s order denying Respondents’ motion to compel arbitration, holding (1) because Plaintiffs did not unambiguously assent to arbitration, the agreement to arbitrate was unenforceable; (2) the ICA erred by placing dispositive weight on procedural unconscionability without addressing the alleged substantive unconscionability of the arbitration terms; and (3) the ICA erred by concluding that Plaintiffs had failed to demonstrate procedural unconscionability. View "Narayan v. Ritz-Carlton Dev. Co." on Justia Law

Since 1993, Defendant claimed lawful ownership of a property that was fraudulently transferred to him as part of a conspiracy to prevent Plaintiffs from collecting on a judgment. After two remands, a third jury found that the transfer of certain property was fraudulent and awarded $253,000 in special damages and $1,642,857 in punitive damages. Defendant appealed, arguing that the punitive damages award was grossly excessive and in violation of his rights under the Fourteenth Amendment. The intermediate court of appeals (ICA) vacated the punitive damages award. The Supreme Court vacated the ICA’s judgment, holding that the punitive damages awarded by the third jury was justified and did not violate Defendant’s federal due process rights. View "Kekona v. Bornemann" on Justia Law