Justia Hawaii Supreme Court Opinion Summaries

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 vacated the judgment of the intermediate court of appeals (ICA) upholding an order and judgment of the probate court that modified a trust provision regarding the distribution of trust principal without issuing findings of fact to explain or support its ruling, holding that the ICA erred.On appeal from the judgment of the ICA, Appellants argued that the ICA erred by weighing conflicting evidence to determine the settlor's intent and ignoring other evidence to resolve an ambiguity in the trust without holding a hearing and by affirming the probate court's decision to deny Appellants any financial information regarding the trust despite the trustee's statutory duty to produce this information. The Supreme Court vacated the ICA's judgment on appeal, holding (1) the absence of factual findings by the probate court did not enable to the ICA to meaningfully review the basis of the probate court's order modifying the trust, and the ICA erred in relying on selective extrinsic evidence; and (2) the ICA erred when it concluded that the terms of the trust can supersede the trustee's statutory duty to provide accounts information to contingent beneficiaries of the trust. View "In re Elaine Emma Short Revocable Living Trust Agreement" on Justia Law

In this appeal arising from a 2014 petition by the Bank of Hawai'i (BOH) to resign as trustee for a trust comprised of several parcels of land underlying the Discovery Bay condominium complex in Waikiki, the Supreme Court vacated in part and affirmed in part the intermediate court of appeals' (ICA) judgment on the appeal, holding that the ICA erred when it decided that Michael David Bruser and Lynn Bruser were liable for the trustee's fees.The Brusers, who held the leasehold commercial unit in the condominium, and several trust beneficiaries objected to BOH's petition to resign as trustee. The probate court permitted BOH to reform the trust agreement and determined that a $9,850 monthly trustee's fee was reasonable. The ICA determined that the Brusers were responsible for paying the trustee's fees and that the monthly trustee's fee was reasonable. The Supreme Court held (1) the ICA erred in concluding that the Brusers were liable for the trustee's fees when the probate court did not address the issue; and (2) the ICA properly affirmed the probate court's conclusion that a $9,850 monthly trustee's fee was reasonable. View "In re Trust Agreement dated June 6, 1974" on Justia Law

Christopher Haig and Myrna Murdoch, two beneficiaries of a testamentary trust created under the will of Samuel Damon, objected to the probate court’s approval of the trust’s accounts from 1999 to 2003. The intermediate court of appeals (ICA) affirmed the probate court’s judgment. Christopher and Myrna separately applied for a writ of certiorari asserting that their due process rights were violated when they were not granted access to documents disclosed to the court-appointed master by the trustees of the trust, which prevented them from making informed objections to the master’s reports regarding the trusts’ accounts during the relevant time period. The Supreme Court reversed, holding that the ICA erred in affirming the probate court’s approval and adoption of the master’s report without first granting the beneficiaries’ requests to access trust administration documents, in violation of the requirements of Haw. Rev. Stat. 560:7-303. View "In re Trust Created Under the Will of Samuel M. Damon" on Justia Law

This case arose from the administration of two irrevocable trusts (together, the trusts) established by Richard and Rachel Ishida. The trusts named as beneficiaries the Ishidas’ daughters Jeri Wilson and Juney Ishida and their granddaughter Kaki Wilson, but the trusts expressly excluded the Ishidas’ third daughter, Deenie Kimora. Six years after they created the trusts the Ishidas requested rescission of both trusts, alleging that they did not intend to make the trusts irrevocable and that Jeri had wrongfully transferred ownership of property from one trust to herself. The probate court ordered the property transferred by Jeri returned to the trust but declined to rescind or reform the trusts. The intermediate court of appeals affirmed. The Supreme Court affirmed, holding (1) the probate court did not err in denying the Ishidas’ requested relief because the matter was within the court’s equitable discretion; and (2) the ICA properly found that the probate court was not required to accept at face value the Ishidas’ petitions, which were verified pursuant to Hawai’i Probate Rules Rule 5(a). View "In re Ishida-Waiakamilo Legacy Trust" on Justia Law

At issue in this case was a nonjudicial foreclosure on real property conducted pursuant to Haw. Rev. Stat. 667-5. The circuit court entered final judgment in favor of the Mounts, the purchasers of the real property through the nonjudicial foreclosure sale, and U.S. Bank National Association. The final judgment was entered against the personal representative of the decedent’s estate. The circuit court ruled that a nonjudicial foreclosure conducted pursuant to section 667-5 is exempt from the time limits for presentation of claims against a decedent’s estate and that U.S. Bank did not violate section 667-5(c)(1) by failing to provide former co-personal representative Sesha Lovelace with information she requested regarding the required funds to reinstate the loan (“reinstatement figures”). The Supreme Court vacated the circuit court’s final judgment, holding (1) a nonjudicial foreclosure conducted pursuant to section 667-5 is not exempt from the time limits under Haw. Rev. Stat. 560:3-803 for presentation of claims against a decedent’s estate; and (2) the nonjudicial foreclosure was conducted in violation of section 667-5(c)(1) when U.S. Bank failed to provide Lovelace with loan reinstatement figures, and this failure rendered the nonjudicial foreclosure sale voidable at the Estate’s election unless the Mounts were innocent purchasers for value. Remanded. View "Mount v. Apao" on Justia Law

This dispute revolved around the administration of two trusts established by now-deceased Thomas H. Gentry. When the beneficiaries and co-trustees disputed how the trust assets should be distributed, the parties entered into a settlement agreement. Petitioner, a beneficiary of both trusts, filed a petition to enforce settlement agreement and appoint receiver. The probate court denied Petitioner’s petition to enforce (enforcement judgment) and granted in part and denied in part the co-trustees’ petition for instructions regarding the distribution of the assets (distribution judgment). Petitioner appealed from the enforcement judgment, arguing that the probate court ignored the settlement agreement in refusing to grant her petition to enforce. The Intermediate Court of Appeals (ICA) concluded that because Petitioner had failed to directly appeal the distribution judgment, Petitioner’s appeal of the enforcement judgment constituted a collateral attack on the distribution judgment. Because it was unable to grant Petitioner effective relief, the ICA dismissed her appeal as moot. The Supreme Court vacated the ICA’s judgment, holding that the ICA erred in concluding that Petitioner’s appeal was an impermissible collateral attack and that Petitioner’s appeal was moot. Remanded. View "In re Thomas H. Gentry Revocable Trust" on Justia Law

Plaintiffs filed this action against the Office of Hawaiian Affairs (OHA) trustees, claiming that the OHA trustees breached their fiduciary duties by improperly expending trust funds on Hawaiians, as opposed to native Hawaiians, in violation of Hawaii law and the Hawaii Constitution. The circuit court dismissed the complaint for failure to state a claim upon which relief could be granted. The Supreme Court affirmed, holding (1) the circuit court did not err in dismissing Plaintiff's complaint because it failed to state a claim; and (2) the circuit court did not abuse its discretion in denying Plaintiffs' motion to amend the complaint. View "Kealoha v. Machado" on Justia Law

The instant action arose from an ejectment proceeding involving a dispute as to whether Respondent Wayne Peelua alleged a cognizable claim to the title of certain real property. Petitioner Deutsche Bank filed a complaint alleging that it was entitled to possession of the property. Respondent moved to dismiss the complaint, alleging that the district court lacked jurisdiction over the matter. The court held for Petitioner. The intermediate court of appeals (ICA) vacated the district court order and remanded with instructions to dismiss the case for lack of jurisdiction. The Supreme Court vacated the ICA and affirmed the district court, holding that Respondent's affidavit did not meet the requirements of Dist. Ct. R. Civ. P. 12.1, and therefore, the district court had jurisdiction over Petitioner's ejectment action. View "Deutsche Bank Nat'l Trust Co. v. Peelua" on Justia Law