Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) to the extent it affirmed the denial of Defendant's motion for a deferred acceptance of no contest (DANC) plea, holding that the circuit court's consideration of sexual penetration was an abuse of discretion under the circumstances.Defendant was indicted for the sexual assault of a twelve-year-old and accepted a plea agreement allowing her to plead no contest to an amended charged of sexual assault in the fourth degree. Defendant moved for DANC plea, which the circuit court denied. The ICA affirmed the denial of Defendant's DANC motion. The Supreme Court vacated the judgment below, holding that Defendant's no contest plea to sexual assault in the fourth degree excluded any allegation of sexual penetration. View "State v. Satoafaiga" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) in this dispute regarding payment of uninsured motorist (UM) and underinsured motorist (UIM) benefits to Plaintiff, holding that the circuit court properly excluded evidence related to an unleaded claim but erred in denying Plaintiff's motion to amend complaint solely on the basis of undue delay.Plaintiff, individually and as personal representative of the estate of her son, who died as a passenger in an automobile accident, brought this action seeking a declaratory judgment, arguing that Defendant improperly failed to recognize that UM and UIM coverages totaling $1.2 million were available to her. At issue before the Supreme Court was whether the circuit court erred in granting Defendant's motion to present evidence or in denying Plaintiff's motion to amend complaint. The ICA affirmed. The Supreme Court vacated in part, holding that the circuit court (1) did not abuse its discretion in granting Defendant's motion to preclude evidence; but (2) erred in concluding that Plaintiff could not amend her complaint due to undue delay. View "Carvalho v. AIG Hawaii Insurance Co." on Justia Law

In this case, the Supreme Court clarified the proper timing of Alvarado calculations, which determines the reimbursement due the insurer from a third-party settlement, and the reimbursement process for an insurer when the amount of workers' compensation (WC) benefits the insurer has already dispensed to the employee is less than the amount it owes the employee for its share of attorney's costs and fees for the third-party action.Petitioner received WC benefits from Respondent. Petitioner brought suit against the owner of the building in which she was injured and reached a settlement. Respondent then sought reimbursement of the WC benefits it had paid to Petitioner under Haw. Rev. Stat. 386-8 and Alvarado v. Kiewit Pacific Co., 993 P.2d 549 (Haw. 2000). At issue was whether certain WC benefits that Respondent owed Petitioner were properly classified as "paid compensation" and whether the process of Respondent's reimbursement of WC benefits exceeded the amount it had previously contributed to Petitioner as "paid compensation." The Supreme Court held (1) Alvarado calculations shall be performed based on the date on which the employee receives the third-party recovery; and (2) an insurer's "share" of the attorney's fees and costs the employee incurs while pursuing third-party recovery is based on the insurer's total WC liability. View "Moranz v. Harbor Mall, LLC" on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction for disorderly conduct, holding that the trial court lacked sufficient evidence to convict Defendant of disorderly conduct.Defendant was arrested by lying in front of trucks scheduled to transport telescope components for the Daniel K. Inouye Solar Telescope along with other protestors and then convicted of disorderly conduct. The ICA affirmed the conviction, concluding that the State's evidence was sufficient to support the conviction. The Supreme Court reversed, holding that Defendant's disorderly conduct conviction was unsupported by substantial evidence. View "State v. Kaeo" on Justia Law

The Supreme Court held that the failure of the Honolulu Police Department (HPD) and the prosecutor in this case to comply with the twenty-day and forty-five-day statutory deadlines contained in Haw. Rev. Stat. 712A-7 and 712A-9 applicable to the seizure of Petitioner's property required its return to Petitioner.In 2012, HPD seized twenty-seven Product Direct Sweepstakes (PDS) machines from six Winner'z Zone locations for violating Hawaii's gambling statutes. For two years, while the machines remained in police custody, HPD did not initiate foreclosure proceedings, give notice of the seizure of forfeiture to all parties, or provide the prosecutors a written request for forfeiture. In 2014, HPD "re-seized" the PDS machines, and the prosecutor initiated forfeiture proceedings. The Supreme Court held that the agency was required to return the seized property because the agency failed to commence forfeiture proceedings according to the specific timing requirements set forth in sections 712A-7 and 712A-9. View "Kaneshiro v. Eleven Products Direct Sweepstakes Machines" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) affirming the family court's order denying Father's motion to set aside default and his motion to intervene, holding that the family court should have analyzed Father's motion to intervene under Hawai'i Family Court Rules (HFCR) 24.In this proceeding brought under the Hawai'i Child Protective Act, Haw. Rev. Stat. Chapter 587A, both Father's default and default judgment were entered while the identity of the child's natural father was unknown. On certiorari, Father argued that he was not required to set aside the default and default judgment before filing his motion to intervene pursuant to Rule 24. The Supreme Court agreed on that issue and otherwise affirmed, holding (1) Father was not required to set aside the default and default judgment before proceeding with his motion to intervene; and (2) Father's remaining arguments were without merit. View "In re AA" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) affirming the district court's order on motion for summary judgment and judgment, holding that the ICA erred when it affirmed the district court regarding Plaintiff-buyers' claims alleging unfair or deceptive acts or practices (UDAP) remaining after summary judgment.Following the execution of two purchase agreements, Buyers took possession of the vehicle in dispute in this case, which, unbeknownst to Buyers at the time, had a defective clutch assembly. Seller refused to repair the vehicle at no cost to Buyers or to return Buyers' deposit. Buyers brought this action alleging that Seller had engaged in UDAP. The district court granted summary judgment for Seller and then entered judgment against Buyers on all remaining claims. The ICA affirmed. The Supreme Court vacated the lower courts' judgments in part, holding that the district court erred in interpreting Haw. Rev. Stat. 481J-2 to conclude that the warranty for used motor vehicles does not cover a clutch assembly. View "Leong v. Honolulu Ford, Inc. " on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) determining that the criminal complaint against Defendant did not comply with Haw. Rev. Stat. 805-1 but that a non-compliant complaint could still be used to initiate and maintain a prosecution by penal summons, holding that the family court erred in issuing a penal summons.The State charged Defendant by complaint with abuse of a household or family member, but the complaint was neither signed by a complainant nor supported by a declaration. The family court issued a penal summons compelling Defendant to appear. After appearing, Defendant filed a motion to dismiss, arguing that the complaint was deficient, and therefore, the family court lacked probable cause to issue the penal summons. The family court granted the motion to dismiss. The ICA vacated the family court, concluding that the district court did not err in issuing the penal summons. The Supreme Court reversed, holding (1) section 805-1 does not distinguish between complaints for penal summons and complaints for arrest warrants; and (2) therefore, the ICA erred in holding that the State need not comply with its statutory obligations simply because it sought a penal summons. View "State v. Thompson" on Justia Law

The Supreme Court held that the gravity of a crime, by itself, does not establish an exigency empowering law enforcement officers to bypass the warrant requirement and that the State must articulate objective facts showing an immediate law enforcement need for the entry to support a warrantless home intrusion under the exigency exception.The State invoked the exigent circumstances exception to justify a warrantless home entry into Defendant's residence. Defendant was subsequently indicted for attempted murder in the second degree. Defendant moved to suppress the evidence found during the search of his residence, arguing that the police lacked exigent circumstances to enter his residence without a warrant. The trial court granted the motion to suppress. The Supreme Court affirmed, holding that the police entered Defendant's home without exigent circumstances, permission, or a warrant, and therefore, the circuit court properly suppressed the evidence. View "State v. Willis" on Justia Law

The Supreme Court remanded this case to the Leeward Planning Commission (LPC) for proceedings consistent with this opinion, holding that the LPC and the Planning Director of the County of Hawai'i wrongfully denied The Community Associations of Haualali (Hualalai) a hearing and decision on its petition to intervene as a party to contest a special permit application.The special permit application at issue requested approval to use an agricultural parcel of land as an equipment base yard and security dwelling and for stockpiling and crushing natural materials for commercial use. Hualalai, a group of Hawaii County community associations, filed a "Petition for Standing in a Contested Case Hearing," or petition to intervene. The petition was denied. Hualalai appealed, challenging the LPC's failure to issue a decision on Hualalai's petition and objecting to the decision to treat the proceeding as a closed matter. The Supreme Court remanded the case, holding that the actions in this case were made upon unlawful procedure and constituted abuses of discretion. View "Community Ass'ns of Hualalai, Inc. v. Leeward Planning Comm'n" on Justia Law