Justia Hawaii Supreme Court Opinion Summaries

Trustee alleged that Defendants owned an interest in a parcel of land and moved for summary judgment to partition their interest along with the remainder of the parcel. The circuit court granted summary judgment for partition, directed that the parcels be sold at a public auction, and ordered the sale proceeds to be distributed pursuant to court order. Defendants’ property was sold to Trustee at the public auction. The sale was confirmed to Trustee pursuant to a confirmation order. Defendants appealed from the confirmation order. The intermediate court of appeals (ICA) dismissed Defendants’ appeal for lack of jurisdiction because no final judgment had been entered in the case. The Supreme Court vacated the ICA’s dismissal order and remanded to the ICA for disposition of the appeal, holding that the confirmation order met the requirements of appealability under the doctrine announced in Forgay v. Conrad, which addresses the narrow relaxation of the finality rule for orders transferring property. View "Lambert v. Teisina" 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

In April 2010, the State Senate expressly rejected Duane Kanuha's nomination for a second term as a commissioner on the State Land Use Commission (LUC). Following the Senate's rejection, Kanuha continued to serve on the board and to participate in the LUC's consideration of a development project involving the reclassification of agricultural land for urban use. Sierra Club filed an action to disqualify Kanuha from serving on the LUC and to invalidate the actions Kanuha had taken with regard to the development project. The LUC denied the action. That same day, LUC voted to approve the development project. Without Kanuha's vote, the LUC lacked the requisite number of votes to approve the reclassification. The circuit court reversed the LUC's decision and order. The ICA reversed, determining that Kanuha continued to serve as a valid holdover member of the LUC after the Senate's rejection of his nomination for a second term. The Supreme Court reversed, holding (1) Kanuha was not a valid holdover when he voted on the reclassification; (2) Kanuha did not qualify as a de facto member of the LUC; and (3) therefore, Kanuha's actions taken with respect to the reclassification petition were invalid. View "Sierra Club v. Castle & Cooke Homes Haw., Inc. " 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

A homeowners association commenced a judicial foreclosure on Defendant's condominium unit after Defendant failed to pay her association fees and dues. The circuit court subsequently entered a default judgment and foreclosure decree. On May 29, the circuit court confirmed the sale to a third-party purchaser. Defendant filed a motion for reconsideration on the order and judgment confirming the sale. The circuit court did not rule on the motion within ninety days, and the motion was automatically deemed denied on September 5. On October 16, Defendant appealed the May 29 judgment. The intermediate court of appeals (ICA) dismissed Defendant's appeal for untimeliness, concluding that Defendant failed to timely appeal following the deemed denial of a post-judgment tolling motion. Specifically, the ICA determined that Defendant should have filed her notice of appeal by October 5, thirty days after the deemed denial of her motion. The Supreme Court vacated the ICA's dismissal order, holding that when a timely post-judgment tolling motion is deemed denied, it does not trigger the thirty-day deadline for filing a notice of appeal until entry of the judgment or appealable order. Remanded. View "Ass'n of Condo. Homeowners of Tropics at Waikele v. Sakuma" on Justia Law

Respondents, the Castro family, executed a mortgage encumbering their property that was assigned to Petitioner, U.S. Bank. When the Castros defaulted on their loan, U.S. Bank purchased the property at a foreclosure auction. Because the Castros failed to vacate the property as instructed, U.S. bank filed a two complaints for summary possession and ejectment against the Castros. The district court entered a judgment for possession and a writ of possession in favor of U.S. Bank and a separate order granting summary judgment for U.S. Bank. The intermediate court of appeals vacated the district court's judgment, concluding that the district court lacked jurisdiction over the case because the action was one in which title to real estate would come into question. The Supreme Court reversed, holding that the district court properly exercised subject matter jurisdiction over the case because the Castros failed to demonstrate the action was one in which title to the subject property would come into question. View "U.S. Bank Nat'l Ass'n v. Castro" on Justia Law

Aloha Tower Development Corporation filed a petition to expunge a deed restriction on a park requiring that it be preserved as a public park. Scenic Hawaii, Inc. subsequently intervened in the litigation. After a non-jury trial, the land court denied the petition. Scenic Hawaii filed a motion for attorneys' fees and costs under the private attorney general doctrine. The land court granted the request. The intermediate court of appeals (ICA) reversed the award of attorneys' fees. The Supreme Court vacated the judgment of the ICA and affirmed the final judgment of the land court, holding that the land court was correct in awarding attorneys' fees and costs to Scenic Hawaii under the private attorney general doctrine inasmuch as the three prongs of the private attorney general doctrine were satisfied in this case. View "In re Application of Honolulu Constr. & Draying Co., Ltd." on Justia Law

Petitioners, residents of Maui, challenged the Maui County Council's (MCC) passage of two bills related to the development of a residential community on 670 acres of land in Wailea (Wailea 670 project), arguing that MCC and its committee, the Land Use Committee (LUC) failed to satisfy the requirements of the State open meetings law, known as the Sunshine Law. Specifically, Petitioners claimed (1) the recessing and reconvening of two meetings without providing additional notice and opportunity for public oral testimony violated the Sunshine Law; and (2) the circulation of memoranda among the board membership outside a duly noticed meeting violated the Sunshine Law. The circuit court granted judgment in favor of Respondents, MCC, County of Maui, and the land developer. The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the LUC and MCC did not violate the Sunshine Law by reconvening the two meetings beyond a single continuance without posting a new agenda and without accepting public oral testimony at every reconvened meeting; and (2) the MCC violated the Sunshine Law by distributing written memoranda among its members outside of a duly noticed meeting, but the violation did not require invalidation of MCC's passage of the Wailea 670 bills. View "Kanahele v. Maui County Council" on Justia Law

In 1971, Plaintiff began subleasing a half-acre parcel of land that was part of an undivided 1040-acre parcel of property (master parcel). Plaintiff and the master parcel's owner, Princeville Development Corporation, subsequently entered into a license agreement effective until 2003 that included an option to purchase and a right of first refusal. The agreement also contained a provision stating that any holding over after the expiration of the term of the agreement should be on the terms and conditions specified in the agreement. In 2005, the Corporation sold the master parcel to Princeville Prince Golf Course (PPGC). Plaintiff filed a complaint against the Corporation in 2005, praying for specific performance of the option to purchase clause. PPGC was substituted as Defendant. The circuit court dismissed Plaintiff's claim for specific performance, holding that the sale of the master parcel did not constitute a "decision to sell" the premises which would trigger Defendant's right of first refusal. The intermediate court of appeals (ICA) affirmed. The Supreme Court reversed, holding (1) Plaintiff's right of first refusal continued into the holdover period; and (2) the right of first refusal was triggered by the Corporation's decision to sell the master parcel in 2005. Remanded. View "Kutkowski v. Princeville Prince Golf Course, LLC" on Justia Law

Plaintiff brought this suit against the City and County of Honolulu and the State, challenging the approval of a rail project and arguing that state law required that an archaeological inventory survey be completed prior to any approval or commencement of the project. The circuit court granted summary judgment in favor of the City and State on all of Plaintiff's claims. The Supreme Court vacated the circuit court's judgment on Plaintiff's claims that challenged the rail project under Haw. Rev. Stat. 6E and remanded. Plaintiff subsequently requested that the Supreme Court award $255,158 in attorney's fees and $2,510 in costs against the City and State for work performed in the trial court. The Supreme Court (1) granted Plaintiff's request for appellate attorney's fees and costs against the City in the amount of $41,192 in attorney's fees and $343 in costs; (2) and denied Plaintiff's request for trial level fees and costs without prejudice, as Plaintiff's request for fees and costs attributable to work performed at the trial level was more properly within the trial court's discretion. View "Kaleikini v. Yoshioka" on Justia Law