Justia Hawaii Supreme Court Opinion Summaries

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

The Supreme Court reversed the ruling of the family court that the prosecution had proven that DM, a minor who stabbed another minor, had committed attempted assault in the first degree beyond a reasonable doubt, holding that the family court inadequately assessed the circumstances from DM's perspective in rejecting DM's self-defense defense.After a bench trial, during which DM argued that he lacked intent and acted in self-defense, the family court adjudicated DM as having committed attempted assault in the first degree. DM appealed, challenging the court's self-defense-related findings and conclusions. The Supreme Court reversed, holding (1) the family court wrongly rejected DM's defense by inadequately assessing his conduct from his perspective and by misapplying key self-defense elements; and (2) there was not substantial evidence to support the family court's conclusion that the State proved beyond a reasonable doubt that DM's use of deadly force was unjustified. View "In re DM" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that, contrary to Defendant's arguments on appeal, the requirements of Haw. Rev. Stat. 327C-1 does not apply to all criminal cases involving death.Defendant was charged with murder in the second degree. A jury found Defendant guilty of the lesser-included offense of manslaughter based on reckless conduct. The ICA affirmed. The Supreme Court affirmed, holding (1) a death determination under section 327C-1 was not required or implicated under the circumstances of this case because there was sufficient evidence for a reasonable juror to conclude that death was proven beyond a reasonable doubt; and (2) the circuit court did not err in failing to instruct the jury on the lesser-included offense of reckless endangering second. View "State v. Angei" on Justia Law

The Supreme Court vacated the decision of the intermediate court of appeals (ICA) affirming order of the circuit court denying Defendant's motion to dismiss indictment against him, the court's judgment of conviction and sentence, and the later order of restitution, holding that the circuit court abused its discretion by denying Defendant's motion to dismiss the indictment.In his motion to dismiss the indictment against him, Defendant argued that the prosecutor committed prosecutorial misconduct by before the grand jury by improperly eliciting testimony that he had invoked his right to remain silent. The circuit court denied the motion to dismiss, and Defendant entered a no-contest plea to assault in the first degree. The ICA affirmed. The Supreme Court vacated the lower courts' decisions, holding (1) the prosecutor violated Defendant's due process right to a fair and impartial grand jury hearing by eliciting testimony that Defendant invoked his right to remain silent; and (2) the circuit court erred by ordering Defendant to pay $1,461,444 in restitution. View "State v. Borge" on Justia Law

The Supreme Court affirmed the order of the Land Use Commission (LUC) denying Petitioners' petition for a declaratory order challenging the construction of the Thirty Meter Telescope (TMT), holding that Haw. Rev. Stat. 205-2(e) does not authorize the Commission to exclude or enforce certain land uses within conservation districts.Petitioners in this case sought to use the LUC's districting authority in a manner that would compel the removal of all astronomy facilities located within the Astronomy Precinct. The LUC denied the petition, and Petitioners appealed. The Supreme Court affirmed, holding (1) this Court had jurisdiction to directly review Petitioners' appeal; (2) the LUC correctly determined that it lacked jurisdiction to issue the requested declaratory orders; and (3) Petitioners were not entitled to relief on their remaining claims of error. View "In re Petition of Ku'ulei Higashi Kanahele" on Justia Law

In this foreclosure dispute, the Supreme Court held that Haw. Rev. Stat. 514B-146(n) provides a scheme for distributing rents following a lender's foreclosure against an association and that the Association of Apartment Owners of Elima Lani Condominiums (AOAO) may be entitled to all or some of the rent collected for Nationstar Mortgage, LLC in this case.AOAO foreclosed an a unit owned by Thomas and Sarah David for failure to pay common assessments. Thereafter, Nationstar filed a complaint for foreclosure of the Davids' unit, alleging that the Davids had defaulted on their mortgage. The circuit court entered summary judgment and a decree of foreclosure in favor of Nationstar after AOAO came into possession of the unit. Nearly eleven months later after the foreclosure sale of the unit, the circuit court confirmed the foreclosure sale. Before the Supreme Court was whether AOAO was entitled to rents that accrued from the unit during the period between summary judgment and the confirmation of sale. The Supreme Court vacated the circuit court's judgment to the extent it awarded post-foreclosure rents to Nationstar and remanded for a calculation of the amount AOAO was owed from post-foreclosure units, holding that AOAO may be entitled to all or some of the rent collected for Nationstar after summary judgment. View "Nationstar Mortgage, LLC v. Ass'n of Apartment Owners of Elima Lani Condominiums" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing without prejudice the complaints in Appellees' cases, holding that the complaints did not have to comply with Haw. Rev. Stat. 805-1, and the State properly initiated the criminal proceedings against Appellees.The State charged Appellees by complaint with operating a vehicle under the influence of an intoxicant (OVUII). Appellees each filed a motion to dismiss for defective complaint and improper arraignment, arguing that the complaint was not supported by the complainant's signature or a declaration submitted in lieu of affidavit. The district court granted the motions to dismiss and dismissed the cases without prejudice. The State appealed, arguing that the district court erred in concluding that the subject charging instruments were required to comply with section 805-1. The Supreme Court agreed and reversed, holding (1) section 805-1 applies only to complaints for a penal summons or an arrest warrant; and (2) the district court erred in dismissing the complaints charging Appellees with OVUII. View "State v. Mortensen-Young" on Justia Law

The Supreme Court affirmed the decision of the Public Utilities Commission (PUC) rejecting the power purchase agreement between Hu Honua and the Hawai'i Electric light Company, Inc., holding that there was no error in the PUC's decision to reject the power purchase agreement between the parties.At issue was the denial of Hua Honua's request for regulatory approval to supply energy to Hawai'i Island using a biomass power plant. In declining to approve the project on remand, the PUC found that the project would produce massive greenhouse gas (GHG) emissions and significantly increase costs for rate-payers. The Supreme Court affirmed, holding that the PUC understood its public interest-minded mission and properly followed this Court's remand instructions to consider the reasonableness of the proposed project's costs in light of its GHG emissions and the impact on Intervenors' right to a clean and healthful environment. View "In re Haw. Electric Light Co., Inc." on Justia Law

The Supreme Court overruled Maha-ulepu v. Land Use Commission, 790 P.2d 906 (1990), superseded by statute, 2005 Haw. Less. Laws Act 205, 2-3 at 669-71, which held that a use not permitted under Haw. Rev. Stat. 205-4.5(a)(6) could be authorized by special use permit, holding that it was incorrectly decided.At issue was Ho'omoana Foundation's proposed overnight campground development for unhoused and commercial campers on Class B land in an agricultural district in Maui could be authorized by special use permit or whether a district boundary amendment was required. The Supreme Court held (1) the specific exclusion of overnight camps from permitted uses in Haw. Rev. Stat. 205-4.5(a)(6) sets forth that the public and private recreation use of overnight camps is not permitted in Class A and B land in agricultural districts and cannot be permitted by special use permits; (2) Maha'ulepu is overruled; and (3) because the proposed campground project included a public or private recreational overnight camp use, the project required a district boundary amendment. View "Ho'omoana Foundation v. Land Use Comm'n" on Justia Law