Justia Hawaii Supreme Court Opinion Summaries

In this consolidated appeal arising from the rulings of the family court on remand from a published opinion of the intermediate court of appeals (ICA) in a divorce case, holding that the family court abused its discretion in part.The ICA affirmed in part and vacated in part the divorce decree in this case and remanded several issues, including the issue of spousal support, to the family court. After the case was remanded and judgment was made, the ICA held that the family court erred by engaging in a new just and equitable determination on remand, as it was not part of the remand order. The Supreme Court vacated in part and affirmed in part, holding (1) the ICA erred by setting aside the amended spousal support order on the basis that the family court was prohibited to do so on remand because Haw. Rev. Stat. 580-47(a) provided the court with continuing jurisdiction to address issues of spousal support; (2) the family court erred on remand by awarding more spousal support than it determined was required to satisfy Wife's needs; and (3) the family court erred by not holding a hearing on remand to determine whether the spousal support amount should have been amended. View "Jacoby v. Jacoby" on Justia Law

The Supreme Court held that wrongful foreclosures in violation of the power of sale are voidable, rather than void, and to the extent Silva v. Lopez, 5 Haw. 262 (1884), is to the contrary, it is overruled.Plaintiffs' property was foreclosed by nonjudicial foreclosure. Several years later, Plaintiffs sued for wrongful foreclosure and quiet title against various defendants. The circuit court granted Defendants' motion for dismissal of all claims. The intermediate court of appeals (ICA) affirmed as to one defendant and otherwise reversed. Plaintiffs subsequently filed an application for a writ of certiorari. The Supreme Court vacated the ICA's judgment as to the one defendant, holding (1) the "tender rule" was inapplicable on the facts, and as to the defendant who sought to assert the tender rule was not Plaintiffs' mortgagee, Plaintiffs did not need to plead tender to establish superior title as to that defendant; and (2) wrongful foreclosures in violation of the power of sale are voidable, not void. View "Delapinia v. Nationstar Mortgage LLC" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's Haw. R. Pen. P. 35(b) motion to reduce his sentence for negligent homicide in the first degree and two drug-related charges, holding that the trial court did not abuse its discretion in denying Appellant's Rule 35(b) motion.The circuit court imposed two concurrent five-year terms of imprisonment to run consecutively with a ten-year term of imprisonment. In his Rule 35(b) motion, Appellant requested that his five-year sentences run concurrently, rather than consecutively, with his ten-year sentence. The circuit court denied the motion, and the intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding that courts deciding Rule 35(b) motions are not required to consider the Haw. Rev. Stat. 706-606 sentencing factors. View "State v. Cattaneo" on Justia Law

The Supreme Court vacated the judgment of the intermediate appellate court (ICA) and the circuit court's order denying Appellant's eighth Haw. R. Pen. P. Rule 40 petition for post-conviction relief, holding that Appellant raised colorable claims in his petition.Appellant was convicted of murder and sentenced to life imprisonment. In his eighth Rule 40 petition, Appellant argued that the trial court erred by ordering restitution without first determining whether Appellant could afford it and that it was error that he be denied parole for nonpayment of restitution. The circuit court denied the petition without holding a hearing. The ICA affirmed. The Supreme Court vacated the orders below, holding (1) Appellant stated a colorable claim that the Hawai'i Paroling Authority denied parole due to nonpayment of restitution; and (2) State v. Johnson, 711 P.2d 1295 (Haw. 1985), did not create a "new rule," and the ICA erred in concluding that the Johnson rule did not retroactively apply to Defendant's sentence. View "Rapozo v. State" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) vacating the circuit court's judgment of conviction and sentence and remanding the case to the circuit court for further proceedings, holding that the appellate court erred in part.Defendant was convicted of computer fraud in the third degree and fraudulent use of a credit card and sentenced to five years in prison. The ICA vacated Defendant's convictions and remanded the case. The Supreme Court vacated the ICA's judgment in part, holding (1) the ICA properly held that aggregation of multiple transactions under computer fraud in the third degree is permissible; and (2) the indictment was defective with respect to the count alleging computer fraud, and therefore, the denial of Defendant's motion to dismiss the indictment was error. View "State v. Shaw" on Justia Law

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