Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court held that, in foreclosure cases in which a deficiency judgment is entered, the traditional process by which Hawai'i courts calculate a deficiency judgment can result in unjust enrichment, and therefore, the equities weigh in favor of adopting the method of calculating a deficiency judgment employed by a majority of other jurisdictions because the majority rule protects all parties to the mortgage.Mortgagors defaulted on their loans, the property was sold, and the foreclosure sale process was less than the amount due on the mortgage. The mortgagee waited more than four years before it attempted to collect a deficiency judgment. Mortgagors argued that the traditional method for calculating a deficiency judgment is unfair and asked that the Court adopt the majority approach, in which the greater of the fair market value as of the date of the foreclosure sale or the sale prices of the property is deducted from the money owed when calculating the deficiency. The circuit court granted a deficiency judgment, and the intermediate court of appeals affirmed. The Supreme Court vacated the lower courts' judgments and remanded the case, holding that this Court adopts the majority approach to calculating deficiency judgments, and the adoption of the majority rule is prospective in effect. View "HawaiiUSA Federal Credit Union v. Monalim" on Justia Law

In this commercial landlord-tenant dispute 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 finding that Tenant was not entitled to damages and that Tenant's claims for equitable relief were moot, holding that the ICA erred in two of its holdings.Landlords performed a self-help eviction after Tenant allegedly breached the lease. Tenant filed this complaint alleging violations of Haw. Rev. Stat. 654-1, 480-2, 480-13, and 480-13.5, and intentional infliction of emotional distress and requesting injunctive relief and damages. The circuit court concluded that Tenant was not entitled to damages because two of the breaches were material and that Tenant's equitable relief claims, including a claim for replevin seeking access to his personal property, were moot. The ICA vacated the circuit court's judgment. The Supreme Court vacated the ICA's judgment in part, holding that the ICA (1) correctly found that the breaches were not material; (2) should not have analyzed the merits of the replevin claim because Tenant had already retrieved his personal property at the time of trial; and (3) misapplied the law of equitable relief because all the equitable claims were moot. View "Kahawaiolaa v. Hawaiian Sun Investments, Inc." on Justia Law

In Father's third appeal in a divorce proceeding the Supreme Court reversed the judgment of the intermediate court of appeals (ICA) except to the extent it affirmed the family court's order denying Father's motion for relief from judgment, holding that the ICA erred in determining that the family court's orders orders denying Father's motion to amend and motion for new trial were void and that both motions were untimely.After the family court entered a divorce decree Father submitted to the family court a Hawai'i Family Court Rules (HFCR) Rule 52(b) motion to amend, a HFCR Rule 59 motion for new trial, and a HFCR Rule 60(a) motion for relief from judgment. The family court denied Father's motion to amend and motion for new trial. The ICA determined that the family court's orders denying Father's motion to amend and motion for new trial were void and that both motions were untimely. The Supreme Court reversed, holding (1) the ICA erred in holding that the motions to amend and for new trial were untimely; (2) the family court had jurisdiction to enter the orders; and (3) the family court did not abuse its discretion in denying Father's motion to amend and motion for new trial. View "DL v. CL" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for escape in the second degree but remanded the matter to the circuit court for calculation of Defendant's presentence detention credit consistent with this opinion, holding that the circuit court erred when it denied Defendant's credit for time serve on the sentence imposed for the escape conviction.Defendant was serving a term of life imprisonment when he left the Laumaka Work Furlough Center in Honolulu and did not return. A jury later convicted Defendant of escape in the second degree, and the circuit court imposed a five-year prison term to run concurrent to his life sentence. The circuit court denied Defendant credit for time served. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's judgment on appeal, holding that the ICA erred in affirming the circuit court's decision denying Defendant credit for time served on his escape conviction. View "State v. Abihai" on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) vacating the order of the circuit court dismissing the charge against Defendant for possession of a dangerous drug in the third degree, holding that the ICA erred in holding that, in order to prevail on a motion to dismiss a possessory drug violation as de minimis, a defendant must prove that the possessed drugs could not have any pharmacological or physiological effect.The charge against Defendant stemmed from the discovery that he was in possession of .005 grams of a substance containing cocaine. The circuit court found that the violation was de minimis and dismissed the charge. The ICA vacated the circuit court's order, determining that the circuit court erred in finding that the cocaine possessed by Defendant could not have had any pharmacological or physiological effect upon consumption. The Supreme Court reversed, holding (1) the record supported the determination that Defendant's violation was de minimis because the possessed drug was neither usable nor saleable; and (2) therefore, the circuit court did not abuse its discretion in dismissing the charge. View "State v. Melendez" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the judgment of the family court convicting Defendant on two counts of sexual assault in the first degree, holding that the ICA did not err in affirming the family court.At issue on appeal was the jurisdiction of the family court to try Defendant and the propriety of instructing the jury on a lesser included offense. The ICA affirmed, concluding that the family court had subject matter jurisdiction pursuant to Haw. Rev. Stat. 571-14(a)(1) and that there was no rational basis to support an instruction of the lesser included offense of sexual assault in the third degree. The Supreme Court affirmed, holding (1) although the jury should have been instructed to determine jurisdictional facts, the error was harmless; and (2) the family court was not obligated to instruct the jury on the lesser included offense of sexual assault in the third degree. View "State v. Malave " on Justia Law

The Supreme Court primarily affirmed the judgment of the intermediate court of appeals (ICA) affirming the judgment of the circuit court convicting Defendant of various counts, including attempted murder of a police officer, and sentencing Defendant to life imprisonment without the possibility of parole plus ten years, holding that the issues Defendant raised on certiorari lacked merit.In his application for writ of certiorari to the Supreme Court Defendant raised five questions, including the issue of whether the ICA committed grave errors of law and fact when it held that the trial court properly admitted evidence of Defendant's suicide attempt the day after the shooting. The Supreme Court addressed Defendant's question regarding his suicide attempt, holding (1) evidence of a suicide or attempted suicide is not automatically admissible as relevant to a defendant's consciousness of guilt, and (2) the circuit court correctly ruled that the evidence was admissible as probative of Defendant's identity as to the person who had committed the offenses charged. Further, the Court noted plain error affecting Defendant's substantial rights with respect to the lack of a merger instruction on Defendant's firearms convictions and remanded the relevant counts to the circuit court for further proceedings. View "State v. Martin" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction of sexual assault in the first degree on the complaining witness pursuant to Haw. Rev. Stat. 707-730(1)(b), holding that the ICA did not err in affirming the family court.Specifically, the Supreme Court held (1) the jury should have been instructed to determine jurisdictional facts, but the error was harmless beyond a reasonable doubt; and (2) the ICA did not err in finding that there was no rational basis in the record to support providing the jury instruction of the lesser included offense of sexual assault in the third degree. View "State v. Malave" on Justia Law

The Supreme Court vacated the order of the intermediate court of appeals (ICA) dismissing this appeal on the grounds that appellate jurisdiction was lacking, holding that the circuit court did not abuse its discretion in finding the existence of "excusable neglect" under Haw. R. App. P. (HRAP) 4(a)(4)(B) to allow an extension of time to file a notice of appeal.Petitioner appealed from the circuit court's judgment in this labor dispute, asserting appellate jurisdiction pursuant to HRAP Rule 4. The ICA dismissed the appeal for lack of appellate jurisdiction, determining that the appeal was untimely under Rule 4(a)(1) because Petitioner did not establish excusable neglect to extend the time to file the notice of appeal. After clarifying the terms "good cause" and "excusable neglect" for purposes of the current HRAP Rule 4(a)(4)(A) and (B), the Supreme Court vacated the ICA's judgment and remanded this case to the ICA to address the merits of the appeal, holding that "excusable neglect" existed in this case, and therefore, the ICA erred in dismissing Petitioner's appeal for lack of appellate jurisdiction. View "Eckard Brandes, Inc. v. Department of Labor & Industrial Relations" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the family court's challenged rulings concerning child custody and relocation and disqualification of counsel in a divorce proceeding, holding that the ICA did not err.Specifically, the Supreme Court held that the ICA did not err by (1) (a) considering the family court’s April 26, 2018 amended findings of fact and conclusions of law regarding child custody despite its entry of some findings of fact regarding child custody before the March 26, 2018 notice of appeal because the notice of appeal was premature; and (b) rejecting Petitioner’s arguments that the April 26, 2018 findings and conclusions should be rejected because the family court adopted Respondent's submissions verbatim; (2) affirming the family court’s denial of its motion to disqualify Respondent’s counsel and law firm; and (3) affirming the family court’s grant of sole physical custody of the parties’ minor children to Respondent and allowing Respondent to relocate the children to Arizona. View "DL v. CL" on Justia Law