Justia Hawaii Supreme Court Opinion Summaries

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

The Supreme Court vacated the summary disposition order of the intermediate court of appeals (ICA) and the order of the circuit court dismissing Appellant's Haw. R. Pen. P. 40 petition, holding that the circuit court erred in dismissing the petition without first providing Appellant an opportunity to clarify his claims.Appellant was convicted of second-degree murder and several other charges. While an inmate, Appellant filed a Rule 40 petition alleging, without any factual allegations, that he received ineffective assistance of counsel at trial. After the circuit court dismissed the petition as "patently frivolous and without a trace of support" Appellant moved to withdraw his petition so he could amend it to include factual allegations. The circuit court denied the motion to withdraw the petition, and the ICA affirmed. The Supreme Court vacated the lower courts' order, holding (1)the circuit court's order dismissing Appellant's petition for postconviction relief was premature because the court failed to provide Appellant with an opportunity clarify his petition before dismissing it; and (2) the motion to withdraw, which should have been construed as a motion to reconsider, should have been granted. View "Lindsey v. State " on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) concluding that the family court erred in dismissing count two of this complaint charging Defendant with certain offenses on the grounds that the family court lacked subject matter jurisdiction over that count, holding that the ICA did not err.Count one of the operative complaint charged Defendant with abuse of a family or household member, and count two charged him with third degree assault against a complaining witness. The family court granted Defendant's motion to dismiss count two, concluding that it lacked subject matter jurisdiction. The ICA reversed, concluding that the family court had concurrent subject matter jurisdiction over the charge based on Haw. Rev. Stat. 571-14(b). The Supreme Court affirmed, holding (1) the family court erred in dismissing count two for lack of subject matter jurisdiction because section 571-14(b) provided the family court with concurrent subject matter jurisdiction over count two; and (2) the family court continued to have subject matter jurisdiction over count two despite the dismissal of count one with prejudice. View "State v. Milne" on Justia Law

In this case concerning the admissibility and evidentiary weight of documents and declarations in a foreclosure proceeding the Supreme Court affirmed the amended judgment and order of the circuit court granting Plaintiff's motion for summary judgment and for interlocutory decree of foreclosure, holding that promissory notes are not hearsay.Plaintiff, U.S. Bank, brought this foreclosure action. The circuit court granted Plaintiff's motion for summary judgment, but the intermediate court of appeals (ICA) remanded the case. At issue on remand was whether U.S. Bank possessed the promissory note when it filed its complaint. The circuit court concluded that U.S. Bank possessed the promissory note at the time it brought suit. The ICA vacated the circuit court's judgment, concluding that U.S. Bank lacked standing because it had not established it possessed the promissory note at the time it filed the foreclosure action. The Supreme Court vacated the ICA's judgment and affirmed the judgment of the circuit court, holding (1) promissory notes are not hearsay; (2) copies of promissory notes are not self-authenticating under Haw. R. Evid. 902(9); (3) under the incorporated records doctrine, business records may be admissible even absent testimony concerning the business practices or records of their creator; and (4) U.S. Bank was entitled to summary judgment. View "U.S. Bank Trust, N.A. v. Verhagen" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) vacating the circuit court's judgment affirming the decisions of the Maui Planning Commission approving an application for a special management area (SMA) use permit to build affordable housing and denying a petition to intervene in the SMA use permit application proceedings, holding that further proceedings were necessary.The SMA use permit was sought by Stanford Carr Development, LLC's (Carr), which sought to build affordable housing within the County of Maui's SMA. The Protect and Preserve Kahoma Ahupua'a Association (PPKAA) filed a petition to intervene in the proceedings. The Commission denied PPKAA's petition on the grounds that PPKAA failed to demonstrate that its interests were different from those of the general public and then approved the SMA use permit application. The ICA vacated the judgment. The Supreme Court affirmed, holding (1) PPKAA had standing to intervene as a matter of right and was denied procedural due process to protect its constitutional right to a clean and healthful environment; and (2) the Commission was required to make findings on the project's consistency with the general and community plans pursuant to Haw. Rev. Stat. 205A-26(2)(C). View "Protect & Preserve Kahoma Ahupua'a Ass'n v. Maui Planning Commission" on Justia Law

In this case involving the binding effect of a stipulation, the Supreme Court vacated in part the judgment of the intermediate court of appeals (ICA) and the circuit court's judgment with respect to the circuit court's order denying sanctions, but otherwise affirmed, holding that the lower courts erred by failing to treat the stipulation at issue as a binding agreement.Plaintiff brought a complaint for foreclosure against Defendants. After summary judgment was granted to Plaintiff but before any foreclosure sale, the parties entered into a stipulation filed with the court providing that the foreclosure sale would be continued while Defendants pursued a private sale. One defendant later filed a motion to compel and for sanctions, asserting that other defendants had blocked the transaction in contravention of the stipulation. The court denied the motion, and the property was subsequently sold at auction. The ICA affirmed, concluding that the circuit court's finding that there was no agreement for a private sale was not clearly erroneous. The Supreme Court reversed in part, holding that a stipulation made during the course of litigation that is reduced to writing, agreed to by all parties, and filed with the court generally operates like a contract and generally binds the parties to its terms. View "Provident Funding Associates, L.P. v. Gardner" on Justia Law

The Supreme Court vacated Defendant's conviction and sentence for four counts of sexual assault in the second degree, holding that Defendant presented a "fair and just reason" for the withdrawal of his pleas of no contest to the counts.Before sentencing, Defendant moved to withdraw his no contest pleas, asserting that he was innocent and wanted a trial. The circuit court denied the motion, concluding that Defendant entered his pleas knowingly, voluntarily, and intelligently. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the trial court's judgment, holding that the trial court disregarded the principle that pre-sentence defendants are entitled to withdraw their pleas for any fair and just reason and that there was a fair and just reason for the withdrawal of Defendant's pleas. View "State v. Pedro" on Justia Law

In this appeal stemming from three separate criminal cases related to repeated violations of an injunction against harassment the Supreme Court vacated the circuit court's orders of resentencing and revocation of probation in two cases and vacated the circuit court's order sentencing Defendant in another case, holding that the circuit court erred.Defendant pled no contest in two cases to eleven counts of violating an injunction against harassment and was sentenced to probation. Two years later, Defendant was convicted of one count each of violating an injunction against harassment and of second-degree assault. At sentencing, the circuit court revoked Defendant's probation in the prior two cases based on Defendant had violated the terms of his probation. The court then sentenced Defendant to a total of seventeen years imprisonment. The Supreme Court vacated Defendant's sentence, holding that the record did not reflect that Defendant understood the consequences of stipulating to the State's motions to revoke probation and that the circuit court did not sufficiently justify the imposition of consecutive sentences for each count. View "State v. Sandoval " on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's order granting summary judgment in favor of Wells Fargo Bank, N.A. on its complaint seeking judicial foreclosure of the residence of Marianne Fong, holding that genuine issues of material fact precluded summary judgment.In order to prove that Fong had defaulted, Wells Fargo submitted a ledger without providing an explanation as to how to read the ledger. The Supreme Court reversed, holding (1) in the absence of any explanation, the ledger was subject to interpretation and therefore presented a genuine issue of material fact; and (2) there was a genuine issue of material fact regarding whether Fong actually owed the amounts that forced her into her alleged default. View "Wells Fargo Bank v. Fong" on Justia Law