Justia Hawaii Supreme Court Opinion Summaries

This case involves a dispute over the Mauna Kea Access Road (MKAR) in Hawaii, which partially lies on Hawaiian home lands. The plaintiffs, who are Native Hawaiian beneficiaries of the Hawaiian home lands trust, sued the State of Hawaii and several of its departments, alleging that they breached their trust duties by allowing the State to use MKAR lands without payment since the 1970s. They also argued that the State's attempt to designate MKAR as a state highway in 2018 was ineffective as a matter of law.The lower court granted summary judgment in favor of the defendants, based on Act 14 of 1995, which was intended to resolve all controversies relating to the Hawaiian home lands trust that arose between 1959 and 1988. The defendants argued that Act 14 remedied the uncompensated use of the Hawaiian home lands underlying the MKAR and made enforcement of a land exchange the exclusive remedy for the plaintiffs.The Supreme Court of the State of Hawaii disagreed with the lower court's ruling. The Supreme Court held that Act 14 of 1995 does not preclude the plaintiffs' claims, that the portion of the MKAR going through Department of Hawaiian Home Lands (DHHL) lands is not a state highway because legal requirements for such a designation were not satisfied, and that the State breached its constitutional and fiduciary obligation to faithfully carry out the Hawaiian Homes Commission Act, 1920. The Supreme Court vacated the lower court's judgment and remanded the case for further proceedings. View "Kanahele v. State" on Justia Law

This case involves a dispute over property ownership between Rosalinda Ganir Saplan and Recto Ramos Saplan (the Saplans) and U.S. Bank. After the Saplans defaulted on their mortgage, U.S. Bank foreclosed on the property and filed an ejectment action against the Saplans in 2011. However, U.S. Bank failed to schedule a required pretrial conference, leading the circuit court to dismiss the ejectment action for want of prosecution. The Saplans then filed a quiet title action in 2015, arguing that the dismissal of the 2011 action had quieted title in their favor. U.S. Bank moved for summary judgment, arguing that the Saplans had not submitted any evidence in support of their claim of title. The circuit court granted the motion.The Intermediate Court of Appeals (ICA) held that the 2011 dismissal was on the merits for the purposes of claim preclusion, but it did not preclude U.S. Bank’s later action because the parties across these lawsuits were different. The ICA also held that summary judgment was improperly granted because U.S. Bank had not provided evidence that its foreclosure sale was fair, reasonably diligent, and in good faith, and the price was adequate.U.S. Bank appealed to the Supreme Court of the State of Hawai‘i, arguing that the ICA erred in holding that the 2011 dismissal was on the merits for the purposes of claim preclusion and that U.S. Bank had not met its burden of showing there were no genuine issues of material fact for trial. The Supreme Court held that without a final judgment, there cannot be claim preclusion. Here, there was no final judgment, so there can be no claim preclusion against U.S. Bank. The court also held that the ICA incorrectly applied the summary judgment standard when it held that U.S. Bank had not met its burden. Because this is the Saplans’ quiet title action, the Saplans have the burden of proof on the issue of property ownership. The court vacated the ICA’s judgment and affirmed the circuit court’s judgment. View "Saplan v. U.S. Bank" on Justia Law

The case involves Juan Angel Rubalcaba, a homeowner, who filed a wrongful foreclosure lawsuit against the Association of Apartment Owners of Makakilo Cliffs. The central issue was whether the mortgage debt of the homeowner to a third-party lender, which was discharged by the third-party lender's subsequent foreclosure, should be considered in determining the plaintiff's damages.The Circuit Court of the First Circuit sought guidance on this issue and forwarded a reserved question to the Supreme Court of the State of Hawai'i. The Supreme Court accepted the question, indicating that it would provide an answer through a related case, Wong v. Ass'n of Apartment Owners of Harbor Square, which was then pending before the court.The Supreme Court of the State of Hawai'i, after deciding the Wong case, provided guidance on how a plaintiff may calculate damages in a lawsuit against a condominium association for wrongful foreclosure. The court then remanded the case back to the Circuit Court of the First Circuit for further proceedings consistent with the Wong decision. The court did not provide a specific ruling on the reserved question but indicated that the lower court should follow the precedent set in the Wong case. View "Rubalcaba v. Association of Apartment Owners of Makakilo Cliffs " on Justia Law

This case involves two appeals by West Maui Resort Partners LP and Ocean Resort Villas Vacation Owners Association against the County of Maui. The appellants, who manage nearly 700 time share units, challenged their Maui County tax assessments, arguing that the County's tax assessments were unconstitutional and violated the County's own code. They contended that the County's creation of a Time Share real property tax classification acted as an illegal tax on time share visitors. They also argued that time share units and hotel units have an identical "use" for real property purposes, and therefore, should be taxed in the same real property tax classification.The Tax Appeal Court granted summary judgment for the County in both cases. The court concluded that the County acted within its constitutional authority to tax real property in creating the Time Share classification and taxing properties assigned to it. The court also found that the County had several legitimate policy purposes rationally related to the creation of the Time Share classification, including raising revenue for infrastructure maintenance and addressing time share properties' unique impacts on the community.The appellants appealed to the Intermediate Court of Appeals, which transferred the cases to the Supreme Court of the State of Hawai‘i. The Supreme Court affirmed the Tax Appeal Court's summary judgment for the County in both cases, concluding that the County did not exceed its constitutional authority when creating the Time Share classification, nor did it violate its own code in doing so. The court also held that the Time Share classification's creation and rates were constitutional under the equal protection clauses of the Hawai‘i and U.S. Constitutions. View "In Re: West Maui Resort Partners LP v. County of Maui" on Justia Law

The case revolves around attorney fees in a dispute involving the Board of Land and Natural Resources (BLNR), State of Hawaii, and the Sierra Club. In 2022, the BLNR approved permits allowing Alexander & Baldwin, Inc. and East Maui Irrigation Company, LLC to divert water from East Maui streams. The Sierra Club appealed this decision, arguing that the BLNR unlawfully denied its request for a contested case hearing. The environmental court modified the permits and capped the amount of water that could be diverted. The BLNR then petitioned the Supreme Court of the State of Hawaii, alleging that the environmental court's decision resulted in a water shortage that hindered firefighting efforts during a wildfire.The environmental court had previously sided with the Sierra Club, ruling that the BLNR should have held a contested case hearing. The court also invoked Hawaii Revised Statutes (HRS) § 604A-2(b) and HRS § 91-14(g) to modify the permits, and cited public trust doctrine principles to support the cap on water diversion. The court decided not to void the permits entirely to avoid potential chaos and threats to the reliable availability of necessary water.The Supreme Court of the State of Hawaii held that a state-initiated original proceeding is not protected by sovereign immunity, and thus, the state may be liable for reasonable attorney fees spent opposing a frivolous petition for extraordinary relief. The court concluded that the Sierra Club is entitled to attorney fees, as the BLNR's petition was found to be frivolous and made in bad faith. The court rejected the BLNR's invocation of sovereign immunity, stating that the state waives its sovereign immunity when it initiates an original action. View "Board of Land and Natural Resources v. Crabtree" on Justia Law

In the Supreme Court of the State of Hawaii, four plaintiffs, Sonia Davis, Jessica Lau, Lauralee Riedell, and Adam Walton, challenged the actions of the County of Maui, the County of Maui Office of the Mayor, and other related defendants. The dispute arose from a sweep of a large encampment of houseless individuals in Maui County in September 2021. The plaintiffs had requested a contested case hearing before the sweep, which was ignored, and the sweep proceeded as planned, leading to the seizure of Davis and Lau's personal property.The plaintiffs asserted they were denied procedural due process under the state and federal constitutions when the county seized their personal property without proper notice or an opportunity to be heard. The County moved to dismiss, arguing the plaintiffs did not have a protected property interest in continuing to store their belongings on County land. The circuit court granted the motion as to Riedell and Walton, who had not lost property during the sweep, but denied the motion as to Davis and Lau, who had.The Supreme Court affirmed the circuit court's decision. The court held that plaintiffs possessed a property interest in their personal items protected by the Constitution of the State of Hawaii. Therefore, the due process clause required a hearing before the County could seize the plaintiffs’ property. The circuit court properly granted the County’s motion to dismiss Riedell and Walton’s claims because they did not lose property during the sweep and properly denied the County’s motion to dismiss as to Davis and Lau, who did. View "Davis v. Bissen" on Justia Law

The Supreme Court of the State of Hawaii addressed the calculation of damages in cases where a condominium association wrongfully forecloses on a unit owner. Stephen Wong, the plaintiff, had bought a condo in the Harbor Square complex, financing his purchase with a mortgage. He fell behind on his association assessments, and the Association of Apartment Owners (AOAO) of Harbor Square non-judicially foreclosed under Hawaiʻi Revised Statutes (HRS) Chapter 667. The foreclosure exceeded the AOAO’s statutory authority, leading Wong to sue for wrongful foreclosure. The court held that damages in such a case are the plaintiff's positive equity in the property, if any, plus lost use arising from the wrongful foreclosure, minus assessments owed to the AOAO. If the plaintiff was "underwater" on their mortgage (owing more than the home's fair market value), they could still potentially pursue a claim if the value of their wrongly taken use exceeds what they owe the AOAO in assessments. In Wong's case, he failed to establish lost use value, leading the court to affirm the lower court's grant of summary judgment to the AOAO. View "Wong v. Association of Apartment Owners of Harbor Square" on Justia Law

In a case regarding the timing of appeals, the Supreme Court of the State of Hawaii has clarified the interpretation of Hawaii Rules of Appellate Procedure (HRAP) Rule 4(a)(3). The case arose from a tax dispute between taxpayers Schuyler and Marilyn Cole and the City and County of Honolulu, leading to a consolidated appeal with other similar cases. In July 2017, the Tax Appeal Court granted summary judgment to the City, and the Taxpayers filed a motion for reconsideration. However, the court failed to rule on this motion within 90 days, and the court's clerk did not provide notice of automatic denial of the motion, as required by HRAP Rule 4(a)(3).The Supreme Court held that if the court clerk does not notify the parties within 5 days after the 90th day that a post-judgment motion has been automatically denied, the time to appeal starts either when the clerk provides notice to the parties or when the court enters a nullified order. The Court also held that judicial inaction cannot operate to foreclose a right to appeal. As a result, the Taxpayers' appeal clock started when the court issued its late order on the motion for reconsideration, and they filed their appeal within the 30-day window from that point, therefore the Intermediate Court of Appeals had jurisdiction over the appeal.The Supreme Court expressed concern about the potential for indefinite extension of the appeal deadline due to court and clerk oversight and suggested that the Standing Committee to Review the Hawaii Rules of Appellate Procedure may wish to consider proposing an amendment to HRAP Rule 4(a)(3). The case was remanded to the Intermediate Court of Appeals for further proceedings. View "Cole v. City and County of Honolulu" on Justia Law

Christopher Wilson was charged with offenses related to carrying a firearm and ammunition in public without the appropriate license in Hawaii. In response, Wilson challenged the constitutionality of the relevant Hawaii Revised Statutes (HRS) § 134-25 (2011) (pistol or revolver) and § 134-27 (2011) (ammunition), arguing that these laws violated his rights under the Second Amendment of the U.S. Constitution and its equivalent in the Hawaii constitution, article I, section 17. The Circuit Court of the Second Circuit dismissed the charges, agreeing with Wilson's argument. The State appealed the dismissal.The Supreme Court of the State of Hawaii concluded that Wilson was only entitled to challenge the constitutionality of the laws he was charged with violating. As such, Wilson could challenge HRS § 134-25 and § 134-27, but not HRS § 134-9, which pertains to licenses to carry firearms and which Wilson had not attempted to comply with.The court found that the text, purpose, and historical tradition of the Hawaii Constitution do not support an individual right to carry firearms in public. The court reasoned that the language of article I, section 17, which mirrors the Second Amendment, ties the right to bear arms to the context of a well-regulated militia. It does not extend this right to non-militia purposes. The court also considered Hawaii's history of strict weapons regulation and the intent of Hawaii's framers.Based on these considerations, the court held that HRS § 134-25 and § 134-27 do not violate Wilson's right to keep and bear arms under article I, section 17 of the Hawaii Constitution and the Second Amendment to the U.S. Constitution. The court vacated the lower court's dismissal order and remanded the case back to the Circuit Court of the Second Circuit. View "State v. Wilson" on Justia Law

In the case before the Supreme Court of the State of Hawai‘i, the issue was whether a subrogee insurance company, which timely intervened pursuant to HRS § 386-8(b), has an independent right to continue to pursue claims and/or legal theories against a tortfeasor that were not asserted by the subrogor employee, after summary judgment has been granted against the subrogor employee, on the subrogor employee’s claims. This case involved Hyun Ju Park, a bartender who was shot by an off-duty Honolulu Police Department officer while at work. Park sued the City and County of Honolulu, alleging negligence and other claims. Dongbu Insurance Co., Ltd., the workers' compensation insurance carrier for Park's employer, intervened in the case, alleging additional negligence claims that Park had not raised. The City moved to dismiss all of Park’s claims and some of Dongbu's claims, which the court granted, leaving two of Dongbu's claims - negligent supervision and negligent training - remaining. The City then moved for summary judgment against Dongbu, arguing that since Park's claims were dismissed, Dongbu's claims also failed.The Supreme Court of Hawai‘i held that a subrogee insurance company, which timely intervened, does have an independent right to continue to pursue claims and/or legal theories against a tortfeasor that were not asserted by the subrogor employee, even after summary judgment has been granted against the subrogor. The court reasoned that an affirmative answer protects subrogation, aligns with Hawai‘i’s workers’ compensation subrogation law, and does not undermine employers’ and insurers’ intervention rights. The court also rejected the City's claim preclusion argument, stating that Dongbu's remaining claims for negligent supervision and negligent training had not yet been decided and were not barred by res judicata. Therefore, Dongbu may continue to pursue its non-dismissed claims. View "Park v. City and County of Honolulu" on Justia Law