Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the intermediate court of appeals affirming Defendant's judgment of conviction and sentence for second-degree assault, holding that the circuit court erred by failing to instruct the jury on second-degree reckless endangering.At the close of trial, the circuit court instructed the jury on assault in the second and third degrees. The jury convicted Defendant of second-degree assault. In his application for writ of certiorari, Defendant argued that the circuit court was required to instruct the jury on reckless endangering in the second degree. The Supreme Court agreed, holding (1) reckless endangering in the second degree is a lesser-included offense of assault in the second degree; and (2) because there was a rational basis to acquit Defendant of assault in the second degree and to convict him of reckless endangering in the second degree, the circuit court erred when it failed to instruct the jury accordingly. View "State v. Manuel" on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) in this appeal, holding that the ICA erred when it vacated the jury's civil conspiracy verdict, when it vacated an order of the circuit court on judicial admissions and judicial estoppel, and when it vacated the jury's verdict on Plaintiff's nuisance, invasion of privacy, and malicious prosecution claims.In this dispute between Plaintiff and Defendants over an easement located on Defendants' property that escalated into numerous incidents of alleged wrongful conduct by both parties, both parties appealed a $616,000 jury verdict in favor of Plaintiff. The ICA vacated the circuit court's judgment, vacated the entire jury award, and remanded the case for a new trial, holding that the circuit court made numerous errors. The Supreme Court reversed and reinstated the jury's award, holding (1) the ICA erred in vacating the circuit court's determination that Defendants judicially admitted to the existence of the easement and that its scope included vehicular ingress and egress; and (2) the ICA erred in several other respects. View "Ching v. Dung" on Justia Law

The Supreme Court affirmed the ICA's judgment on appeal except that part of the judgment relating to an additional revocation period for having three or more prior alcohol enforcement contacts, holding that the procedures used by the Administrative Driver's License Revocation Office (the ADLRO) denied Defendant due process.The ADLRO sustained the automatic revocation of Defendant's driver's license for ten years, determining that Defendant was subject to a mandatory ten-year revocation period for operating a vehicle under the influence of an intoxicant because he had three or more prior alcohol enforcement contacts. The ICA affirmed. The Supreme Court vacated the ICA's decision in part, holding that the ADLRO erred in considering two prior alcohol enforcement contacts in determining the length of Defendant's revocation period because Defendant was unable to challenge those convictions at the revocation hearing. View "Wolcott v. Administrative Director of the Courts" on Justia Law

In response to a question certified to it by the United States Court of Appeals for the Ninth Circuit the Supreme Court answered that the statute of limitations for a regulatory takings claim brought under the Hawai'i Constitution is six years pursuant to the catch-all statute of limitations in Haw. Rev. Stat. 657-1(4).The underlying dispute arose from the State Land Use Commission's (LUC) reclassification in 2011 of 1,060 acres of land in South Kohala on Hawai'i Island. In 2017, DW Aina Le'a Development (DW) filed this complaint alleging that the reclassification was an unconstitutional taking because the LUC failed to compensate DW for damages resulting from the land's reclassification. The federal district court dismissed the case, applying the two-year statute of limitations found in Haw. Rev. Stat. 657-7. LW appealed, arguing that the "catch-all" six-year statute of limitations applied to the action. The Ninth Circuit certified to the question to the Supreme Court. The Supreme Court held that the statute of limitations for a takings claim under the Hawai'i Constitution is six years pursuant to Haw. Rev. Code 657-1(4). View "DW Aina Le'a Development, LLC v. State Land Use Commission" on Justia Law

The Supreme Court dismissed this election complaint challenging the result of the Office of Hawaiian Affairs (OAH) at-large trustee election in the November 3, 2020 general election, holding that Plaintiff Keoni Souza did not provide specific facts or actual information of mistakes, errors, or irregularities sufficient to change the result of the election.Souza was a candidate in the OHA at-large trustee election. Keli'i Akina received the highest number of votes, and Souza received 1,623 fewer votes than Akina. In this complaint, Souza asserted five claims for relief, alleging, among other things, that Act 135, as codified at Haw. Rev. Stat. 11-158, is arbitrary and that a recount was warranted. The Supreme Court granted Defendants' motion to dismiss, holding (1) Souza failed to demonstrate that Act 135 is arbitrary or flawed such that the results of the OHA at-large trustee election would be different; and (2) Souza was not entitled to relief on any remaining allegations of error. View "Souza v. Ige " on Justia Law

The Supreme Court reversed the denial of relief and dismissal of Appellant's Hawai'i Rules of Penal Procedure (HRPP) Rule 40 petition, holding that Appellant was entitled to appropriate relief because Appellant's counsel was ineffective.Appellant was convicted of promoting a dangerous drug in the second degree and prohibited acts related to drug paraphernalia. The intermediate court of appeals (ICA) affirmed. After the deadline had passed for filing a writ of certiorari, Appellant filed an application for writ of certiorari challenging the ICA's decision. The Supreme Court dismissed the application because it was untimely. Appellant then filed a pro se petition for post-conviction relief pursuant to Rule 40, alleging that he was denied effective assistance of counsel because appellate counsel failed timely to apply for writ of certiorari despite assuring Appellant that she would do so. The circuit court denied relief. The ICA affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) appellate counsel was ineffective; and (2) appropriate relief in this case was allowing Appellant to refile an application for writ of certiorari in his original case so that the Supreme Court can decide to accept or reject it on the merits. View "Villados v. State" on Justia Law

The Supreme Court answered a certified question by concluding that, under Hawai'i law, a permissive user of an insured vehicle, whose connection to the vehicle is permission to use the vehicle to run errands and drive to work, was entitled to uninsured motorist (UM) benefits under the chain-of-events test because he was injured by an uninsured motorist.The Supreme Court determined that the proper inquiry under the chain of events test was whether a permissive user has retained a sufficient connection to the insured vehicle. The Court then held that, under the chain of events test, the driver at issue was entitled to UM benefits because he was a permissive user of the insured vehicle during the chain of events resulting in his injury caused by an uninsured motor vehicle. View "State Farm Mutual Automobile Insurance Co. v. Mizuno" on Justia Law

The Supreme Court ordered that this Court's August 27, 2020 order regarding temporary extension of the time requirements under Hawai'i Rules of Penal Procedure Rule 5(c)(3) for first circuit criminal matters is further extended until December 31, 2020, concluding that a further extension of the August 27 order was necessary.On August 27, 2020 the Supreme Court entered the order at issue, which provided that the first circuit may temporarily extend the time requirements for preliminary hearings no longer than reasonably necessary to protect public health and safety during the COVID-19 pandemic. Because COVID-19 cases have remained high since then, the Court extended the order until November 16, 2020. Here, the Court determined that a further extension of the August 27, 2020 order was necessary and thus extended the order until December 31, 2020. View "In re Judiciary's Response to the COVID-19 Outbreak" on Justia Law

In this divorce proceeding, the Supreme Court adopted the California Supreme Court's test for voluntariness in premarital agreements (PMA) under the Uniform Premarital Agreement Act (UPAA) and held that the family court did not err in enforcing the PMA in this case and that Wife's other asserted points of error were meritless.During the parties' divorce proceeding, Wife argued that she involuntarily executed the PMA prior to her marriage to Husband. The family court rejected Wife's argument and enforced the PMA. The Supreme Court affirmed the judgment of the intermediate court of appeals and the family court, holding that the family court did not err by (1) considering the custody evaluator's report in awarding full physical custody of the parties' minor child to Husband; (2) finding that the PMA was enforceable; and (3) failing to find that Husband abused the temporary restraining order process to gain advantage in the custody dispute. View "L.R.O. v. N.D.O." on Justia Law

The Supreme Court held that res judicata does not preclude a Haw. R. Civ. P. 60(b) motion for relief from judgment in a foreclosure proceeding and that the circuit court did not abuse its discretion in denying Appellant's Rule 60(b) motion in this case.The circuit court found Appellant in default on her mortgage and granted summary judgment in favor of Respondent. Before a foreclosure sale took place, Appellant filed a Rule 60(b) motion, challenging Respondent's standing to bring a foreclosure action against her. The circuit court denied the motion. The intermediate court of appeals affirmed, ruling that res judicata precluded Appellant's post-judgment Rule 60(b) motion. The Supreme Court affirmed on different grounds, holding (1) res judicata did not bar Appellant's Rule 60(b) motion; but (2) the circuit court properly denied the Rule 60(b) motion because there were no extraordinary circumstances warranting extraordinary relief under Rule 60(b)(6). View "Pennymac Corp. v. Godinez" on Justia Law