Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court reversed the order of the circuit court dismissing the second "Felony Information and Non-Felony Complaint" brought by the State recharging Defendant after the circuit court dismissed the charging document as insufficient, holding that, under the facts of this case, the circuit court erred.Defendant was charged with several crimes arising from a hit and run. Defendant moved to dismiss the charges on the grounds that the charging language was fatally insufficient. The circuit court granted the motion, and the State appealed. Thereafter, the State recharged Defendant, attempting to correct the inadequacies identified in the first charging document. The circuit court dismissed, for lack of jurisdiction, the second charging document while the first charging document remained pending on appeal. The Supreme Court reversed, holding that Defendant's filing of the notice of appeal in the first case did not strip the circuit court of jurisdiction over the second case. View "State v. Michaeledes" on Justia Law

The Supreme Court vacated the opinion of the intermediate court of appeals (ICA) reversing the order of the circuit court granting summary judgment in favor of Defendant in this insurance broker malpractice case, holding that the circuit court and the ICA majority incorrectly analyzed Defendant's burden regarding the causation element.Plaintiff brought negligence and negligent malpractice claims against Defendant. In the original proceedings, judgment was granted for Plaintiff. The ICA remanded the case to the circuit court to include previously excluded testimony. On remand, the circuit court granted summary judgment for Defendant. The ICA reversed. The Supreme Court vacated the ICA"s order and remanded the case to the circuit court for further proceedings, holding (1) to negate the causation element of the negligence and negligent malpractice claims against it Defendant would need to demonstrate that Plaintiff's insurer (Insurer) would not have been legally obligated to advance Plaintiff's defense costs even if Plaintiff's grand jury subpoena matter were timely tendered to Insurer; and (2) the lower courts incorrectly analyzed Defendant's burden regarding the causation element, requiring remand. View "Pflueger, Inc. v. AIU Holdings, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for four counts, including murder in the second degree, holding that, under the circumstances of this case, there was no need for a "determination of death" within the meaning of Haw. Rev. Stat. 327C-1.Section 327C-1 defines the process for making "death determinations in the State" in all "civil and criminal actions." During Defendant's criminal trial, the medical examiner who performed the victim's autopsy testified that the cause of the victim's death was a gunshot wound to the head. Nine days after the verdict was rendered, Defendant filed a motion for arrest of judgment and dismissal, arguing that the circuit court lacked jurisdiction over his case because the State failed to show at the grant jury proceeding that the victim had been determined to be brain dead. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the State was not required to met the requirements of section 327C-1 to prove the victim's death; and (2) Defendant's remaining arguments on appeal lacked merit. View "State v. Moon" on Justia Law

In this election contest, the Supreme Court entered judgment in favor of Defendants and against Plaintiffs as to all claims stated in the complaint, holding that Plaintiffs failed to establish a viable election challenge that would "cause a difference in the election results."The election result contested in this case was for the office of council member for the Wailuku-Waihe'e-Waikapu seat on the Maui County Council. On November 22, 2022, the final result was reported that Alice Lee received the most votes, with Nolan Ahia receiving 513 fewer votes. Plaintiffs, Ahia and thirty voters who resided within the election district, brought this complaint challenging the election result. The Supreme Court ordered that Lee received a majority of the votes cast and had been elected to the seat of the Wailuku-Waihe'e-Waikapu councilmember, holding that Plaintiffs' claims were unavailing. View "Ahia v. Lee " on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals' upholding Defendant's convictions for burglary in the first degree and other crimes, holding that the State caused an unreasonable delay in sentencing Defendant and that the unreasonable delay deprived Defendant of the opportunity for allocution.Specifically, the Supreme Court held (1) the State caused an unreasonable delay in sentencing, thus depriving Defendant of due process and a sentencing proceeding that was fundamentally fair, in violation of Haw. Const. art. 1, 5 and the Fourteenth Amendment to the federal Constitution; and (2) the State's unreasonable delay in sentencing Defendant deprived him of the opportunity to allocution, in violation of Haw. Const. art. I, 5. View "State v. Canosa" on Justia Law

The Supreme Court held that, in petitions for adoption and permanent placement, a family court is free to consider any admissible evidence that addresses the best interests of the individual, including evidence supporting some best interests factors listed in Haw. Rev. Stat. 571-46(b).In 2018, the Department of Human Services (DHS) assumed temporary foster custody of two children under the Child Protective Act (CPA) and placement them with resource caregivers (RCGs). In 2020, Father stipulated to the termination of his parental rights. The children's aunt and uncle (Relatives) intervened in the CPA's permanent placement and adoption proceedings. DHS filed a petition on behalf of RCGs to adopt the children. Relatives responded by filing their own petition to adopt the children. The family court consolidated the dual adoption cases and found that adoption by the RCGs was in each child's best interest. The intermediate court of appeals affirmed. The Supreme Court affirmed, holding that a family court does not necessarily err when it relies on HRS 571-46(b)'s mandatory custody and visitation factors to guide a best interest determination in adoption and placement proceedings. View "In re ASK" on Justia Law

The Supreme Court dismissed this election complaint asserting that the November 8, 2022 primary election ballot violated Haw. Const. art. II, 4 and Haw. Rev. Stat. 12-31 and that James Malish should have been included in the 2022 general election ballot because he was unopposed as a nonpartisan candidate, holding that Plaintiffs were not entitled to relief.Plaintiffs Karl Dicks, an unsuccessful Republican candidate for the office of State Senator, District 17, and Malish, the only nonpartisan candidate in the primary election for the office of State Senator, District 9, brought this pro se complaint asserting that the primary election ballot unconstitutionally required selection of a political preference and that the manner in which it displayed a nonpartisan candidate could be construed to require declaration of a political preference when selecting a nonpartisan ballot. The Supreme Court dismissed the complaint, holding that the election complaint failed to state a claim on which relief may be granted. View "Malish v. Nago " on Justia Law

The Supreme Court vacated the opinion of the intermediate court of appeals (ICA) affirming the order of the circuit court granting summary judgment against Jonah Ke'eaumoku Kapu and in favor of Makila Land Co., LLC on Makila's paper title claim to real property in Maui and denying Kapu's claim for ownership of the property by adverse possession, holding that the circuit court abused its discretion.At issue before the Supreme Court was whether a letter from Kapu should have been liberally construed by the circuit court as a motion for reconsideration of the order granting summary judgment to Makila Land Co., LLC, an order that resulted in Kapu losing his home. The Supreme Court agreed with Kapu on appeal, holding (1) Kapu's pro se letter should have been liberally construed as a motion for reconsideration pursuant to the Supreme Court's policy to afford pro se litigants equal access to justice; and (2) the circuit court erred in failing to provide Kapu an opportunity to be heard on the merits of that motion. View "Makila Land Co., LLC v. Kapu" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court denying Defendant's motion to dismiss the counts against him, holding that Defendant was not entitled to relief on his allegations of error.Defendant was indicted for leaving the scene of an accident involving death or serious bodily injury (count one) and negligent homicide in the second degree (count two). After a trial, the jury found Defendant guilty on both counts. Before sentencing, Defendant moved to dismiss count one and count two, arguing that both counts were defective. The circuit court denied the motion to dismiss, and the ICA affirmed. The Supreme Court affirmed, holding that Defendant did not show that the State's indictment violated his right to know the nature and cause of the accusations against him. View "State v. Blyenburg" on Justia Law

The Supreme Court ruled that the intermediate court of appeals (ICA) had jurisdiction to review the merits of Appellant's postconviction appeal even though the appeal was not properly taken from a final order, holding that the appeal's procedural defects stemmed from ineffective assistance of counsel.Appellant pled no contest to murder in the second degree and was sentenced to life in prison with the possibility of parole. The ICA dismissed Appellant's appeal for lack of appellate jurisdiction because the appeal had not been taken from a final order. The Supreme Court vacated the ICA's decision, holding (1) the order appealed from was not final, and the appeal did not give rise to appellate jurisdiction; and (2) this Court presumes prejudice to Appellant from his counsel's failure to take the procedural steps necessary to make the appeal that Appellant desired, and the appropriate remedy is consideration of the appeal on its merits. View "Suitt v. State" on Justia Law