Justia Hawaii Supreme Court Opinion Summaries

In this original proceeding, the Supreme Court entered judgment dismissing this complaint asking the Court to nullify the results of the August 8, 2020 primary election for the City and County of Honolulu mayoral seat and allow all candidates who choose to continue to the November general election to have their names appear on the ballot, holding that the complaint failed to state claims upon which relief can be granted.Plaintiff was one of fifteen candidates for the City and County of Honolulu mayoral seat in the primary election. Rick Blangiardi and Keith Amemiya received the highest number of votes. Plaintiff brought this action alleging that their were multiple irregularities with the primary election. The Supreme Court dismissed the complaint, holding (1) the city clerk for the City and County of Honolulu was a necessary and indispensable party who should have been named as a defendant; and (2) in any case, the complaint failed to state claims upon which relief can be granted. View "Dicks v. State of Hawai'i Office of Elections" on Justia Law

Given the rising number of COVID-19 cases at the O'ahu Community Correctional Center (OCCC) and the difficulties with social distancing the Supreme Court requested additional information to assist the court and parties in addressing the public health and safety concerns raised by the cluster of COVID-19 cases at OCCC.The Office of the Public Defender (ODP) filed a petition for extraordinary writ and/or a writ of mandamus seeking a reduction of the inmate populations at the State's correctional centers and facilities in an effort to mitigate the harm that COVID-19 may inflict upon the inmates, correctional staff, and general public. The Supreme Court stated that there was an urgent and immediate concern in reducing the inmate populations at OCCC and ordered that the DPS shall provide to the OPD a list of all inmates at OCCC who meet certain criteria. View "In re Individuals in Custody of State of Hawai'i" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals and the circuit court's judgment convicting Defendant of assault in the second degree, holding that the prosecutor's misconduct in this case violated Defendant's due process right to a fair trial.Defendant was convicted of assault in the second degree in connection with an incident involving Defendant's wife (CW). The only witnesses to the incident at the time the injury were Defendant and CW. During trial, the prosecutor made at least eight improper statements during closing argument, and the misconduct affected the central issue to Defendant's self-defense claim of whether he acted with the intent to protect himself. The Supreme Court remanded the case, holding that the strength of the evidence in support of self-defense, the protracted nature of the prosecutorial misconduct, and the court's ineffective curative instructions led to the conclusion that the misconduct was not harmless beyond a reasonable doubt. View "State v. Conroy" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the district court's judgment convicting Defendant of operating a vehicle under the influence of an intoxicant (OVUII), holding that the ICA gravely erred as a matter of law in finding that even if the district court erroneously allowed a police officer to opine that Defendant failed standardized field sobriety tests (SFSTs), the error was harmless.Specifically, the Supreme Court held (1) the district court erred by permitting Officer Joshua Wong to express an expert opinion that Defendant "failed" the SFSTs, and the error was not harmless beyond a reasonable doubt; (2) the district court erred in permitting expert opinion testimony that Defendant had a blood alcohol content of 0.08 or above; (3) the district court did not err in permitting expert opinion testimony that Defendant was intoxicated, but, prospectively, police officers may no longer testify, whether in a lay or expert capacity, that a driver appeared "intoxicated"; and (4) Defendant's conviction was supported by substantial evidence. View "State v. Jones" on Justia Law

The Supreme Court affirmed in part and vacated in part the circuit court's final judgment granting and apportioning monetary damages to Native Hawaiian beneficiaries after ruling that the State breached its duties as trustee of the Hawaiian Home Lands Trust (Trust), holding that the Fair Market Rental Value (FMRV) model is an adequate method for approximating actual damages.Plaintiffs were a group of Native Hawaiian Trust beneficiaries who claimed that they incurred damages while on the waitlist to receive homestead land due to breaches of trust duties by the State. In 2009, the circuit court ruled that the State breached its duties as trustee of the Trust. In 2018, the circuit court entered a final judgment adopting a FMRV model by which it could estimate the actual loss each individual beneficiary incurred. The Supreme Court affirmed in part and vacated in part the circuit court's judgment, holding that the circuit court (1) did not err by adopting the FMRV model; (2) incorrectly ruled that a beneficiary's damages did not begin to accrue until six years after the State received a beneficiary's homestead application; and (3) did not err in finding that the State breached its trust duties by failing to recover lands that were withdrawn from the Trust prior to statehood. View "Kalima v. State" on Justia Law

The Supreme Court granted Defendants' petition for writ of mandamus, holding that the intermediate court of appeals (ICA) manifestly abused its discretion in setting the amount of a supersedeas bond as a condition of staying the enforcement of a judgment and writ of possession pending appeal.The circuit court granted summary judgment in favor of Plaintiff on its complaint for ejectment against Defendants. While Defendants' appeal was pending, Defendants moved for a stay of proceedings to enforce the judgment. The circuit court granted the request and required Defendants to post a supersedeas bond in the amount of $578,000. Defendants then filed a motion for a stay in the ICA. The ICA granted a stay on the condition that it would be effective upon the ICA's approval of a supersedeas bond in the amount of $250,000 (the stay order). Defendants filed a petition for writ of mandamus from the ICA's stay order, arguing that the amount of the supersedeas bond should not exceed $8,000. The Supreme Court granted the petition, holding (1) the ICA not apply relevant factors in setting the bond amount, and (2) the stay order lacked a reasonable timeframe in which Defendants would be required to post the bond. View "Kelepolo v. Fernandez" on Justia Law

In this criminal case, the Supreme Court held prospectively that once the court receives notice pursuant to Haw. Rev. Stat. 407.5(1) that a defendant's penal responsibility is an issue in the case, the circuit court must advise a defendant of the penal-responsibility defense and obtain a knowing waiver of the defense.During the criminal proceedings in this case, two of the three examiners concluded that Defendant lacked penal responsibility. Defendant insisted that he was not mentally ill and that he did not want to assert a defense based on lack of penal responsibility. The circuit court eventually found Defendant was fit to stand trial, and Defendant was found guilty. On appeal, Defendant argued that the circuit court should have either sua sponte instructed the jury about the defense of criminal responsibility or conduct a colloquy to ensure that he knowingly and voluntarily decided not to raise the defense. The Supreme Court affirmed, holding that (1) going forward, courts have a duty to obtain a knowing and voluntary waiver of a penal-responsibility defense; and (2) the trial court followed the rules in place at the time of Defendant's conviction and had no duty to sua sponte instruct the jury on lack of penal responsibility. View "State v. Glenn" on Justia Law

The Supreme Court held that Plaintiff's injury-by-disease was compensable under Hawai'i's workers' compensation law because the employer failed to overcome the presumption in favor of compensability.Plaintiff filed a workers' compensation claim for injury-by-disease. The Labor and Industrial Relations Appeals Board (LIRAB) rejected the claim, concluding that the employer's Independent Medical Examinations (IME) reports provided sufficient substantial evidence to overcome the statutory presumption in favor of compensability. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's judgment and the LIRAB's decision, holding that the employer's IME reports failed to provide substantial evidence to meet its burden to produce evidence that, if true, would overcome the statutory presumption that the injury was work-related. The Court remanded the case to the LIRAB with the instruction that Plaintiff's injury-by-disease was compensable under Hawai'i's workers' compensation law. View "Cadiz v. QSI, Inc." on Justia Law

The Supreme Court vacated Defendant's sentence for theft in the second degree by shoplifting, holding that, pursuant to State v. Auld, 361 P.3d 471 (Haw. 2015), Defendant's sentence violated his right to a jury determination as to whether he qualified to be sentenced as a repeat offender pursuant to Haw. Rev. Stat. 706-606.5.The circuit court sentenced Defendant as a repeat offender to a mandatory minimum of five years' incarceration without the possibility of parole. The circuit court, however, did not require a jury to find that Defendant qualified as a repeat offender beyond a reasonable doubt, as required by Auld. The intermediate court of appeals (ICA) affirmed the conviction and sentence. The Supreme Court vacated the ICA's judgment on appeal and the circuit court's sentence and remanded the case for resentencing, holding (1) Defendant was entitled to the protections of Auld; and (2) the State was required to, but did not, prove Defendant's predicate prior convictions to a jury beyond a reasonable doubt prior to imposition of a mandatory minimum sentence as a repeat offender. View "State v. Means" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the judgment of the district court convicting Defendant of operating a vehicle under the influence of an intoxicant (OVUII), holding that the district court abused its discretion in denying Defendant's motion to compel.Specifically, the Supreme Court held (1) as to Defendant's speedy trial challenges, Haw. R. Penal P. 48 requires a "meaningful" commencement of trial, a trial is "meaningfully" commenced when a trial court reasonably commits its resources to the trial, and this holding applies prospectively to events occurring after publication of this decision; (2) the prosecutor in this case was not required to personally review files of the testifying police officers; and (3) the district court abused its discretion in denying Defendant's motion to compel production of a video recording showing Defendant at the police station after her arrest because the video recording was material to Defendant's defense and her request was reasonable. View "State v. Alkire" on Justia Law