Justia Hawaii Supreme Court Opinion Summaries

In this litigation concerning the future of Mauna Kea, the Supreme Court reversed the order of the circuit court granting in part and denying in part KAHEA: The Hawaiian Environmental Alliance's motion to quash a subpoena with respect to subpoena request numbers five and eight and affirmed the judgment in all other respects, holding that the two subpoena requests were unreasonable.In 2019, the State Attorney General issued a subpoena duces tecum to First Hawaiian Bank commanding the bank to produce eighteen categories of records from KAHEA's accounts. KAHEA moved to quash the subpoena, claiming it was retaliatory harassment brought on by KAHEA's opposition to the construction of an astronomical observatory on Mauna Kea. The circuit court disallowed fifty percent of the subpoena requests. KAHEA appealed, arguing that the entire subpoena should have been quashed. The Supreme Court held (1) the Attorney General's investigatory powers validated the subpoena; (2) KAHEA's First Amendment freedom of speech and retaliation claims failed; and (3) two subpoena requests were unreasonable. View "In re Investigation of KAHEA" on Justia Law

The Supreme Court affirmed the judgment of the circuit court mandating the release of certain records, holding that the Uniform Information Practices Act (UIPA) required the release of the requested records.UIPA mandates disclosure of public records but furnishes an exception for government records which, if disclosed, would constitute a clear unwarranted invasion of personal privacy. Plaintiff, the State of Hawaii Organization of Police Officers (SHOPO), sued under UIPA to prevent the disclosure of certain police misconduct records, claiming that they were subject to the privacy exception. The circuit court dismissed the complaint to the extent SHOPO's claim was based on a violation of the UIPA and denied the motion in all other respects, concluding that SHOPO had no private cause of action for disclosure of government records under the UIPA. The Supreme Court affirmed, holding (1) there is no private cause of action to prevent, as opposed to compel, the release of public records under UIPA; and (2) UIPA required the release of the records. View "State of Hawaii Organization of Police Officers v. City & County of Honolulu" on Justia Law

The Supreme Court vacated Defendant's conviction for assault in the first degree and remanded this case to the circuit court, holding that the trial court erred in conditioning the admission of evidence on expert testimony.Defendant killed his cousin, Santhony Albert, but claimed he had acted in self-defense. Defendant was convicted of assault in the first degree, and intermediate court of appeals affirmed. On appeal, Defendant argued that the trial court erred in preventing him from advancing evidence of Albert's blood alcohol concentration (BAC) level unless he called an expert to explain its meaning. The Supreme Court agreed, holding that the trial court erred in conditioning the BAC evidence on expert testimony and violated Defendant's constitutional right to present any and all competent evidence to support his defense. View "State v. David" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree murder for the death of a minor, holding that, contrary to Defendant's contention on appeal, the jury's answer to a special interrogatory was reconcilable with its verdict that Defendant was guilty of second-degree murder.In its jury instructions, the trial court instructed the jury on the lesser included offenses of second-degree murder, including third-degree assault. The statute defining third-degree assault, Haw. Rev. Stat. 707-712, states that the offense may be reduced to a petty misdemeanor if the altercation is the result of "mutual affray." The circuit court submitted a special interrogatory to the jury on mutual affray and instructed the jury that it must answer the special interrogatory only if it found Defendant guilty of third-degree assault. The jury found Defendant guilty of second-degree murder and answered the special interrogatory in the negative. Defendant filed motion for a new trial, arguing that the jury's inconsistent verdict required that his convictions be vacated. The Supreme Court affirmed, holding that the evidence could have reasonably caused the jury to conclude that the altercation leading to the decedent's death began as mutual affray but ended in second-degree murder. View "State v. Bringas" on Justia Law

The Supreme Court affirmed Defendant's conviction for burglary, holding that the prosecutor committed misconduct but that the evidence overwhelmingly established Defendant's guilt.During Defendant's trial, the prosecution injected victim impact evidence, spotlighting the crime's effect on the burglarized family and focusing its narrative arc on the victims' emotional state and actions after the crime. The prosecutor also told jurors that defense counsel tried to "trick" him. On appeal, Defendant argued that prosecutorial misconduct required that his conviction be vacated. The Supreme Court affirmed, holding (1) the prosecutor committed serious misconduct during trial; but (2) considering the strength of the evidence against Defendant, the misconduct had no reasonable possibility of contributing to Defendant's conviction. View "State v. Riveira" on Justia Law

The Supreme Court vacated Defendant's conviction of possession of methamphetamine and of drug paraphernalia, holding that the admission of certain testimony contravened Haw. R. Evid. 404(b) and 403 because it was propensity evidence that suggested that Defendant was a drug dealer.During trial, Amy Bautista, Defendant's girlfriend, testified for the State about Defendant's prior drug activity. On appeal, Defendant challenged that circuit court's admission of Bautista's statements admitted as prior bad act evidence. The intermediate court of appeals affirmed. The Supreme Court vacated the judgments below, holding that the circuit court abused its discretion when it determined that the probative value of the evidence substantially outweighed its prejudicial effect and that Defendant was entitled to a new trial. View "State v. Villados " on Justia Law

The Supreme Court vacated in part the judgment of the intermediate court of appeals (ICA) vacating the final judgment order of the circuit court in connection with a dispute over whether Hitoshi Yoshikawa was allowed to moor his boat in the Kalele Kai marina, holding that when a judgment upon which attorneys' fees and costs were based has been vacated, the attorneys' fees and costs should also be vacated.The circuit court granted summary judgment in favor of the Association of Owners of Kalele Kai, awarded attorneys' fees and costs, and entered final judgment in favor of the Association. The ICA vacated the summary judgment but affirmed the related attorneys' fees and costs award. The Supreme Court vacated the ICA's judgment to the extent it affirmed the attorneys' fees and costs award, which arose from the vacated summary judgment and vacated the order of the circuit court awarding fees and costs, holding that the ICA abused its discretion by limiting the issues on remand to prevent the circuit court from considering attorneys' fees and costs awarded based on the vacated summary judgment. View "Association of Owners of Kalele Kai v. Yoshikawa" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the circuit court's order denying Defendant's motion for a new trial, holding that the cumulative impact of misconduct on the part of the prosecutor deprived Defendant of a fair trial and was not harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) at trial, the prosecutor introduced to the jury incriminatory statements allegedly made by Defendant without previously disclosing them to the defense during discovery in violation of Haw. R. Pen. P. 16(b)(1); (2) the prosecutor introduced statements that were incriminating to Defendant that were allegedly made by the complaining witness despite the court's motion in limine ruling barring their introduction; (3) the prosecutor engaged in improper and unnecessarily lurid questioning of defense witnesses to inflame the jury's passions; and (4) the circuit court erred in denying Defendant's motion for a new trial based on prosecutorial misconduct, and the ICA erred in concluding that the prosecutor's misconduct was harmless. View "State v. Williams" on Justia Law

The Supreme Court vacated the order of the intermediate court of appeals (ICA) affirming the order of the family court convicting Defendant of abuse of family or household member, holding that the improper admission of certain evidence was not harmless beyond a reasonable doubt.Defendant's conviction stemmed from his act of striking the complaining witness, his wife, in the face. Before trial, the State sought to introduce "prior bad acts" evidence, specifically, a previous incident in which Defendant allegedly pushed his wife out of a chair. The family court ruled that the State could introduce the chair incident if the door was opened by Defendant. During trial, the chair incident was allowed into evidence. The ICA affirmed. The Supreme Court vacated the ICA's decision, holding (1) the ICA erred by ruling that Defendant "opened the door" to the chair incident evidence; (2) the ICA erred by ruling that the chair incident evidence was admissible under Haw. R. Evid. 404(b); (3) the family court's limiting instructions failed to mitigate the prejudicial impact of the chair incident evidence; and (4) the improper admission of the chair incident evidence was not harmless beyond a reasonable doubt. View "State v. Feliciano" on Justia Law

The Supreme Court held that the Public Utilities Commission (PUC) did not abuse its discretion in deciding not to reopen a December 2014 order (Order No. 32600) upon allegations raised in 2019 that changed circumstances warranted relief from the order.The order at issue approved a purchase power agreement (PPA) in which Hawaiian Electric Company agreed to purchase wind energy generated by Na Pua Makani on a wind farm to be constructed on the island of O'ahu. Life of the Land (LOL) sought to reopen the order with reference to Hawai'i Rules of Civil Procedure Rule 60(b). The PUC denied LOL's motion for relief, concluding that it was without jurisdiction to consider the motion because LOL had not timely appealed the order under Haw. Rev. Stat. 269-15.5 and, alternatively, that the motion for relief was an untimely motion for rehearing or reconsideration. The Supreme Court affirmed, holding that the PUC did not abuse its discretion in declining to turn to HRCP Rule 60(b) to reopen Order No. 32600. View "In re Application of Hawaiian Electric Co." on Justia Law