Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the circuit court denying Appellant's Haw. R. Civ. P. 60(b)(6) motion for relief from a judgment of foreclosure, holding that the lender, James B. Nutter Company (JBNC), committed fraud on the court and that the balance of equities weighed against foreclosure.JBNC brought the underlying foreclosure proceeding against Appellant for allegedly defaulting in the observance and performance of the terms, covenants and conditions of his mortgage by failing to make $500 worth of repairs. The circuit court granted JBNC's motion for summary judgment and decree of foreclosure, after which Appellant brought this motion for relief. The circuit court denied relief. The intermediate court of appeals (ICA) affirmed. The Supreme Court reversed, holding that there were grounds for relief both on a fraud on the court theory and under the equitable principles governing foreclosure. View "James B. Nutter & Co. v. Namahoe" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) holding that a plaintiff may not recover attorneys' fees under the private attorney general (PAG) doctrine from a private defendant even where the State voluntarily participated as a co-litigant in the case, holding that the ICA erred.Petitioners prevailed against Defendant Haleakala Ranch Company (HRC) in procuring the circuit court's judgment that the State of Hawai'i and not HRC owned a portion of the Haleakala Trail that ran over HRC's property. At issue before the Supreme Court was Petitioners' attempt to recover attorneys' fees from HRC under the PAG doctrine. The Supreme Court held (1) plaintiffs who recover attorneys' fees and costs under the PAG doctrine may also recover fees and costs reasonably incurred in litigating their initial claim for fees; and (2) a plaintiff may recover attorneys' fees under the PAG doctrine from a private defendant where the State voluntarily participated as a co-litigant in the case. View "Public Access Trails Haw. v. Haleakala Ranch Co." on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Defendant for promoting prostitution in violation of Haw. Rev. Stat. 712-1203(1), holding that a reasonable juror could not have concluded that Defendant profited from prostitution within the meaning of Haw. Rev. Stat. 712-1201.After a jury trial, Defendant was found guilty of promoting prostitution. Defendant filed a motion for judgment of acquittal or, in the alternative, motion for new trial, which the circuit court denied. The intermediate court of appeals affirmed, rejecting Defendant's argument that she could not have profited from prostitution under the facts of this case. The Supreme Court reversed, holding that the State failed to prove that Defendant "profit[ed] from prostitution" within the meaning of section 712-1201(2). View "State v. Ibarra" on Justia Law

In this case challenging the constitutionality of administrative rules governing access to Mauna Kea's summit under Haw. Const. art XII, 7, the Supreme Court answered questions reserved by the Circuit Court of the Third Circuit by holding (1) in a challenge to the constitutionality of administrative rules based on a violation of Haw. Const. art. XII, 7, the burden of proof does not shift to the government agency defendant and instead remains with the challenging party; and (2) the framework set forth in Ka Pa'akai O Ka'Aina v. Land Use Comm'n, 7 P.3d 1068 (Haw. 2000), applies to challenges to the constitutionality of an administrative rule based on an alleged violation of article XII, section 7, in addition to contested case hearings. View "Flores-Case 'Ohana v. University of Haw." on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the judgment of the trial court denying Defendant's motion to correct the credit he received against his sentence, holding that, under Haw. Rev. Stat. 706-671(1), presentence detention time must be counted only once against the aggregate of a defendant's consecutive sentences.The Supreme Court also held (1) under section 706-671(2), time served against concurrently-running probation sentences that are later revoked and converted to consecutive terms of imprisonment must be counted only once against the aggregate of a defendant's consecutive sentences in one or more cases; and (2) when detention or prison time is accrued before sentences or pursuant to a later-revoked probationary sentence, the prohibition on multiple punishments is not violated if the defendant's total period of detention and imprisonment does not exceed the statutory maximum term for the offenses at issue. View "State v. Vaden" on Justia Law

In this criminal case, the Supreme Court held that the district court and intermediate court of appeals (ICA) erred in ruling that Defendant was not entitled to the requisite Miranda warnings when she was questioned by law enforcement officers, holding that "if a person is unable to leave a place of interrogation due to circumstances incident to medical treatment, determining whether the person is 'in custody' under a totality of circumstances requires an inquiry into whether the person was at liberty to terminate the interrogation and cause the officer to leave."State v. Ketchum, 34 P.3d 1006 (Haw. 2001), articulated that a person is "in custody" for constitutional purposes if the totality of the circumstances reflects that the point of arrest has arrived because probable cause to arrest has developed. State v. Sagapolutele-Silva, 511 P.3d 782 (Haw. 2002), overruled Ketchum's bright-line rule and said that the existence of probable cause was only a factor in determining whether someone was entitled to Miranda warnings under the totality of the circumstances. Here, the Supreme Court expressly overruled Sagapolutele-Silva's abrogation of the Ketchum rule and held that the Ketchum rule remained in effect. The Court then held that, based on the totality of the circumstances, Defendant was in custody well before probable cause developed, and therefore, the lower courts erred by holding that Miranda warnings were not required. View "State v. Hewitt" on Justia Law

The Supreme Court affirmed Defendants' convictions for attempted murder in the second degree, kidnapping, and other crimes but remanded the case for a new extended term sentencing hearing and resentencing, holding that that extended term sentencing instructions and special interrogatories were prejudicially erroneous and misleading.The jury selection process in the underlying proceedings identified prospective jurors by a number, not name. On appeal, Defendants argued that the circuit court's jury selection method violated their constitutional right to a presumption of innocence and an impartial jury. The Supreme Court disagreed and affirmed the convictions, holding that there was no constitutional violation. The Court, however, held that Defendants' life without the possibility of parole sentences for attempted murder could stand because the circuit court's extended term sentencing jury instructions and special interrogatories were prejudicially erroneous and misleading. View "State v. Lafoga" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the judgment of the circuit court granting the State's motion for revocation of probation and resentencing Defendant to five years of imprisonment with credit for time served, holding that there was no error.After probation officers conducted a warrantless search of Defendant's home and recovered a firearm and ammunition, the circuit court revoked Defendant's probation. At issue on appeal was whether the circuit court abused its discretion by imposing a probation condition allowing warrantless searches by a probation officer for contraband. The ICA affirmed. The Supreme Court affirmed, holding that because Defendant was prohibited from owning or possessing firearms and ammunition and because he had notice that the term "contraband" would include such items, the circuit court did not abuse its discretion by imposing the special condition. View "State v. Talo" on Justia Law

The Supreme Court affirmed in part, reversed in part and vacated in part the judgment of the circuit court holding that Bristol-Myers Squibb and Sanofi had violated Hawai'i's Unfair or Deceptive Acts or Practices law (UDAP) by misleading the public about the safety and efficacy of their anitplatelet drug, Plavix, holding that remand was required.The circuit court concluded that Defendants misled Hawai'i consumers by failing to warn them that Plavix was less effective for poor responders, granted the State's motion for partial summary judgment, and imposed an $834 million penalty. The Supreme Court (1) reversed the circuit court's deceptive acts or practices holding, holding that the summary judgment ruling circumscribed Defendants' ability to present a full defense and affected the penalty award, requiring a new trial; (2) affirmed the holding that Defendants committed unfair acts under UDAP; and (3) held that Defendants' procedural arguments failed. View "State v. Bristol-Myers Squibb Co." on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) vacating the family court's parental termination order in this case and remanding the action for a new trial, holding that Parents received a fundamentally fair trial and that due process was satisfied.During the underlying termination proceedings, the family court appointed attorneys for Parents, but Parents failed to appear at a court hearing and so the court discharged counsel. When Parents reappeared, the court reappointed counsel, and eventually, after a trial, the family court terminated Parents' parental rights. The ICA vacated the termination order and remanded for a new trial, finding structural error in the discharge of Parents' counsel. The Supreme Court disagreed and reversed, holding (1) a family court's discharge of counsel does not necessarily make a trial fundamentally unfair in Child Protection Act proceedings; and (2) Parents received a fair procedure in this case. View "In re JH" on Justia Law