Justia Hawaii Supreme Court Opinion Summaries

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

The Supreme Court affirmed the intermediate court of appeals' (ICA) amended judgment remanding this custody case to the family court for further proceedings, holding that the ICA did not err by holding that the family court abused its discretion in denying Father's request for a continuance to seek the assistance of an attorney.Mother filed a motion for post-decree relief requesting sole physician and joint legal custody of the parties' two minor children so that she could relocate to North Carolina. Both parties proceeded to trial without attorneys. Father, who had a Tagalog interpreter available at trial, experienced difficulty cross-examining witnesses and orally requested a continuance so that he could obtain the assistance of an attorney. The family court denied as untimely Father's motion. The court then ruled that it was in the children's best interests to relocate with Mother. The ICA vacated the family court's ruling. The Supreme Court affirmed, holding that the family court abused its discretion in denying Father's motion for a continuance. View "DJ v. CJ" on Justia Law

The Supreme Court vacated Defendant's conviction for failing to comply with the requirements of Haw. Rev. Stat. 291C-13, holding that both the complaint and the evidence were insufficient.Section 291C-13 requires that when an accident occurs, the driver that causes damage must stop the vehicle at, or as close as possible to, the accident scene and remain there until the driver has provided certain identifying information. The statute also requires that every such stop be made without obstructing traffic more than necessary. On appeal, Defendant argued that there was insufficient evidence to sustain her conviction because, where it was necessary for the parties to move their vehicles out of traffic, the State was required to prove that the stop at the accident scene could have been made without obstructing traffic more than necessary. Defendant further argued that because the complaint and charge did not allege that "[e]very stop shall are made without obstructing traffic more than is necessary" she was not fully informed of the nature and cause of the accusation against her. The Supreme Court agreed, holding (1) the complaint was insufficient; and (2) the State failed to prove that Defendant did not provide the required statutory information to the police after the accident in this case. View "State v. Baker" on Justia Law

In this case arising from a personal injury lawsuit against the drivers of two vehicles in two separate accidents, one in 2005 and the other in 2008, the Supreme Court affirmed the ICA"s judgment vacating the circuit court's summary judgment in favor of Defendants for the 2008 accident, holding that the circuit court erred.Plaintiff filed a complaint against Leslie Ching for the 2005 accident and Lyanne Kimura for the 2008 accident. Kimura impleaded Dennis Espaniola as a third-party defendant because of his involvement in the 2008 accident. Plaintiff alleged he was able to assert tort liability for the two accidents under either of two exceptions to Haw. Rev. Stat. 431:10C-306(a), which abolishes tort liability with respect to accidental harm arising from motor vehicle accidents occurring in the state. The circuit court ruled that Plaintiff failed to satisfy either exception. The ICA vacated the summary judgment. The Supreme Court affirmed, holding (1) the ICA did not err in ruling that the circuit court erred in granting Espaniola's motion for partial summary judgment based on Plaintiff's failure to satisfy the tort threshold; and (2) the ICA did not err in ruling that the circuit court's grant of Espaniola's motion for partial summary judgment was premature. View "Mobley v. Ching" on Justia Law

In this case concerning the State's refusal to produce the results of an investigation into the Office of the Auditor based in part on the lawyer-client privilege the Supreme Court held that the State may not exclude a government record from disclosure under the Uniform Information Practices Act (UIPA) on the basis of a lawyer-client relationship between two State entities that is asserted but not proved.Honolulu Civil Beat Inc. (Civil Beat) contacted the Department of the Attorney General (the Department) requesting under the UIPA access to copies of investigative reports related to the State Auditor's Office. The State refused to produce any documentation based in part on the lawyer-client privilege and the professional rule protecting confidential lawyer-client communications. Civil Beat filed a complaint alleging that the Department had denied Civil Beat its right to access government records under the UIPA. The circuit court granted summary judgment for Civil Beat. The Supreme Court vacated the circuit court's judgment, holding that the circuit court erred in concluding that the requested record was protected from disclosure under the UIPA by Haw. Rev. Stat. 92F-13(4). Because the court did not address the two other disclosure exceptions asserted by the Department, the Supreme Court remanded the case. View "Honolulu Civil Beat Inc. v. Department of the Attorney General" on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) and the order of the circuit court determining that Appellant qualified as a "plaintiff" for the purpose of the vexatious litigant statute, Haw. Rev. Stat. 634J, and that the required circumstances were met, holding that the lower courts erred in determining that Appellant qualified as a "plaintiff" and that other requirements set forth in the statute were satisfied.Appellee filed a motion to declare Appellant a vexatious litigant under section 634J-1(2) and (3) based on Appellant's repeated assertion of arguments that Appellee contended were already resolved. The circuit court granted the motion, concluding that Appellant met the definition of "plaintiff" because he had, through seven motions, sought to relitigate the merits of a summary judgment order and thereby "maintained" the litigation and that Appellant met the definition of a vexatious litigant. The ICA affirmed. The Supreme Court reversed, holding (1) Appellant did not meet the definition of "plaintiff" under section 634J-1 or 634J-1(2); (2) a finding of bad faith is required in order to conclude a litigant is vexatious under section 634J-1(2) or (3); and (3) the record did not support a finding of bad faith in this case. View "Trustees of Estate of Bernice Pauahi Bishop v. Au" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court granting summary judgment in favor of Defendant and dismissing Plaintiff's complaint alleging that Defendant's cattle trespassed onto his property causing damage to his sweet potato crop, holding that the legislature intended to hold owners of livestock liable for the damage caused by the trespass of their animals on cultivated land whether the land is properly fenced or not.In granting summary judgment for Defendant, the circuit court concluded (1) Hawai'i's statutory law governing the trespass of livestock onto cultivated land did not apply to Plaintiff's property because the property was neither "properly fenced" nor "unfenced"; and (2) a provision in Plaintiff's lease making Plaintiff fully responsible for keeping cattle out of his cultivated land was not void against public policy. The ICA affirmed. The Supreme Court reversed, holding (1) livestock owners are liable for damages caused by their livestock trespassing onto cultivated land; and (2) the lease provision was contrary to statutory law and public policy and was thus invalid because it had the effect of absolving Defendant of liability for livestock damage to Plaintiff's cultivated land. View "Yin v. Aguiar" on Justia Law

The Supreme Court held that the intermediate court of appeals (ICA) did not abuse its discretion by imposing sanctions on two attorneys (together, Counsel) and denying Counsel's motion to reconsider the sanctions orders but that the Office of Disciplinary Counsel (ODC) was not authorized to treat the sanctions orders as administrative dispositions that might be used in any future disciplinary proceedings as evidence of aggravation.In a criminal matter, the ICA sanctioned counsel each in the amount of $50 based on Haw. R. App. P. 51. Counsel filed a motion for reconsideration of the sanctions order, which the ICA denied. The Supreme Court affirmed the ICA's sanctions orders against Counsel but ordered that the clerk of court transmit this opinion to the ODC for appropriate action consistent with this opinion, holding (1) the ICA did not abuse its discretion by imposing sanctions pursuant to Rule 51 and denying the motion for reconsideration; and (2) the ODC was without authority to treat the sanctions orders as administrative dispositions that might be used in the future as evidence of a pattern of conduct in aggravation. View "In re Partington" on Justia Law

The Supreme Court reversed the judgment of the intermediate court of appeals (ICA) affirming the judgment of the circuit court granting Defendants' motion to compel arbitration of Plaintiff's complaint against a partnership and a partner after concluding that Plaintiff's claims arose out of the agreement founding the partnership, signed by Plaintiff, that contained an arbitration clause, holding that the claims in Plaintiff's complaint were not subject to the arbitration clause in the partnership agreement.Plaintiff, a founding partner of the partnership, brought claims alleging conversion, fraudulent conversion, and punitive damages. The lower courts concluded that Plaintiff's claims arose out of the partnership agreement, and therefore the arbitration clause applied. The Supreme Court reversed, holding that because Defendants failed to initiate arbitration pursuant to Haw. Rev. Stat. 658A-9 before filing a motion to compel arbitration and because the arbitration clause did not encompass Plaintiff's claims for conversion, the ICA erred in affirming the circuit court's order granting Defendants' motion to compel arbitration. View "Yamamoto v. Chee" on Justia Law