Justia Hawaii Supreme Court Opinion Summaries

In this ejectment action, the Supreme Court granted Appellant's motion for in forma pauperis (IFP) status on appeal, vacated the Intermediate Court of Appeals' (ICA) order dismissing appeal, and remanded this case to the ICA for further proceedings consistent with this opinion, holding that the ICA abused its discretion in ordering Appellant to file IFP motions in the district court, in denying Appellant's second IFP motion based on Haw. Rev. Stat. 607-3 and Haw. R. App. P. 24, and then in dismissing her appeal.Appellant, a self-represented defendant in a residential ejectment case, appealed a judgment and writ of possession filed by the district court. Appellant filed two motions to proceed IFP. The ICA denied both motions and ordered Appellant either to file an IFP motion in the district court within ten days or pay the filing fees in full. When Appellant did neither, the ICA dismissed Appellant's appeal. The Supreme Court reversed, holding that when courts have discretion in applying court rules or statutes, they must consider the access to justice principle of reducing barriers to the civil justice system for self-represented litigants. View "Estate Administrative Services LLC v. Mohulamu" on Justia Law

The Supreme Court vacated the Intermediate Court of Appeals' (ICA) judgment on appeal and the circuit court's amended judgment convicting Defendant of burglary in the first degree, holding that Defendant was denied the right to effective assistance at trial.On appeal, Defendant argued that her trial counsel provided ineffective assistance by failing to adduce critical evidence impeaching the credibility of the State's key witness. The Supreme Court agreed and vacated Defendant's conviction, holding that, when viewed as a whole, the adequacy of counsel's representation was not within the range of competence demanded of counsel in criminal cases. View "State v. Salavea" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for murder in the second degree, holding that third party culpability evidence was erroneously excluded, but the error was harmless beyond a reasonable doubt.On appeal, Defendant asserted (1) the trial court abused its discretion by excluding evidence tending to show that a third party committed the offense; (2) the trial court erred by admitting into evidence a confession letter allegedly written by Defendant because of its late disclosure to the defense; and (3) DNA results showing Defendant's presence at the crime scene were improperly admitted at trial. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admitting the confession letter at trial because the timing of the State's disclosure did not require exclusion; (2) a sufficient foundation to admit the results of the DNA analyses was established to allow their admission into evidence; and (3) evidence of the third party's culpability was improperly excluded, but the exclusion was harmless beyond a reasonable doubt. View "State v. Texeira" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the judgment of the circuit court convicting Defendant of reckless endangering in the second degree, holding that the circuit court erred by excluding Defendant from presenting third-party culpability evidence at trial.In precluding Defendant from presenting third-party culpability evidence the circuit court determined that the evidence failed to establish a "legitimate tendency" that the third party committed the crime. The Supreme Court vacated Defendant's conviction, holding (1) admissibility of third-party culpability evidence is properly governed by Haw. R. Evid. 401 and 403, without having also to satisfy a legitimate tendency test; (2) the circuit court erred in precluding the defense from adducing third-party culpability evidence that another person assaulted the complaining witness; and (3) the circuit court and the ICA improperly weighed the third-party culpability evidence offered by Defendant. View "State v. Kato" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the judgment of the circuit court convicting Defendant of sexual assault in the first degree and sexual assault in the third degree, holding that Defendant's confession should not have been admitted against him at trial.Defendant gave his confession during a custodial interrogation. At issue on appeal was whether Defendant's constitutional right against self-incrimination was violated by the admission of his confession. The ICA affirmed the circuit court's ruling that the confession was voluntarily given. The Supreme Court reversed, holding (1) due to law enforcement's coercive tactics and deception about incontrovertible physical evidence Defendant's confession was involuntary under the totality of the circumstances; and (2) the admission of Defendant's statement was not harmless error. View "State v. Baker" on Justia Law

In this appeal challenging the circuit court's grant of Defendant's ex parte oral motion to dismiss a personal injury action with prejudice, the Supreme Court held that the circuit court abused its discretion in granting Defendant's motion to dismiss.Plaintiff, a pro se litigant, filed a personal injury claim against Defendant. During a pretrial conference at which Plaintiff did not attend Defendant filed his oral motion to dismiss. The trial court granted the motion. The Supreme Court reversed, holding (1) the circuit court abused its discretion in granting Defendant's oral motion to dismiss with prejudice because the record did not provide a valid basis for the dismissal order, and the court failed to make the request findings of fact that would be required to support such an order; and (2) in general, motions must be made in writing with notice provided unless the motion is made during a hearing or trial. View "Erum v. Llego" on Justia Law

In this case arising from the nonjudicial foreclosure of Petitioner's apartment based on unpaid assessments the Supreme Court reversed the decision of the intermediate court of appeals (ICA) partially affirming the trial court's dismissal of the Petitioner's claims against the apartment owners' association and the purchaser of the property for wrongful foreclosure, holding that the complaint stated a claim against both defendants.Petitioner's claim for wrongful foreclosure was based on the association's lack of a valid power of sale. The district court found that the complaint failed to state a claim upon which relief could be granted because Haw. Rev. Stat. Chapter 667, which governs foreclosures, contained a statutory bar that precluded Petitioner's claims. The ICA concluded that the statutory bar did not preclude Petitioner's claim for damages against the association but did not preclude Petitioner's claim to title of the property against the purchaser. The Supreme Court reversed, holding (1) Petitioner's wrongful foreclosure claim was not limited by chapter 667, and chapter 667's provisions do not bar a claim of wrongful foreclosure based on the lack of a power of sale; and (2) therefore, the complaint did state a claim against both the association and the purchaser of the apartment. View "Sakal v. Association of Apartment Owners of Hawaiian Monarch" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) upholding an order and judgment of the probate court that modified a trust provision regarding the distribution of trust principal without issuing findings of fact to explain or support its ruling, holding that the ICA erred.On appeal from the judgment of the ICA, Appellants argued that the ICA erred by weighing conflicting evidence to determine the settlor's intent and ignoring other evidence to resolve an ambiguity in the trust without holding a hearing and by affirming the probate court's decision to deny Appellants any financial information regarding the trust despite the trustee's statutory duty to produce this information. The Supreme Court vacated the ICA's judgment on appeal, holding (1) the absence of factual findings by the probate court did not enable to the ICA to meaningfully review the basis of the probate court's order modifying the trust, and the ICA erred in relying on selective extrinsic evidence; and (2) the ICA erred when it concluded that the terms of the trust can supersede the trustee's statutory duty to provide accounts information to contingent beneficiaries of the trust. View "In re Elaine Emma Short Revocable Living Trust Agreement" on Justia Law

In this certiorari proceeding arising out of a lawsuit brought by condominium owners whose unit was nonjudicially foreclosed by their association of apartment owners the Supreme Court held that the intermediate court of appeals (ICA) erred in affirming the circuit court's dismissal of the unfair or deceptive acts of practices (UDAP) claim, holding that the Plaintiffs' UDAP claim should not have been dismissed.Plaintiffs filed a complaint against their association (Association), by and through its board of directors (Board), asserting wrongful foreclosure and UDAP claims based on the Board's nonjudicial foreclosure and public sale of their condominium apartment due to unpaid assessment fees. The circuit court dismissed the complaint for failure to state a claim. The ICA held that the circuit court (1) erred in dismissing Plaintiffs' wrongful foreclosure claim, and (2) correctly dismissed the UDAP claim as time-barred. The Supreme Court reversed as to the UDAP claim and otherwise affirmed, holding (1) the ICA correctly reinstated the wrongful foreclosure claim because the Board lacked a power of sale; and (2) based on the applicable notice pleading standard, viewing the complaint in the light most favorable to Plaintiffs, it cannot be said that Plaintiffs can prove no set of facts in support of their claim that would entitle them to relief. View "Malabe v. Ass'n of Apartment Owners of Executive Centre" on Justia Law

The Supreme Court reversed Defendant's conviction of assault against a law enforcement officer in the second degree, holding that the record did not reflect an on-the-record exchange sufficient to constitute the true colloquy required to establish a knowing and intelligent waiver of Defendant's constitutional right to a jury trial.Defendant was convicted after a bench trial. On appeal, Defendant argued that the district court reversibly erred in failing to obtain a valid on-the-record waiver of his constitutional right to a jury trial. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgments of the ICA and the district court, holding that, under the totality of the circumstances, the record did not reflect an on-the-record exchange sufficient to constitute the true colloquy required to establish a knowing and intelligent waiver of Defendant's constitutional right to a jury trial. View "State v. Ernes" on Justia Law