Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court held that Appellant’s extended term sentence was imposed in an illegal manner and, accordingly, vacated the circuit court’s order denying Appellant’s motion for correction of illegal sentence with regard to the extended term sentence.A judge, and not a jury, determined in 2004 that Appellant’s extended term sentence was necessary for the protection of the public, which was contrary to the Supreme Court’s holding in Flubacher v. State, 414 P.3d 161 (Haw. 2018). Accordingly, the Supreme Court vacated the circuit court’s order denying Appellant’s motion for correction of illegal sentence as to the extended term sentence. View "Marks v. State " on Justia Law

At issue was whether the Intermediate Court of Appeals’ (ICA) judgment on appeal, entered pursuant to its memorandum opinion affirming the circuit court’s order granting in part and denying in part Appellant’s petition for postconviction relief, was proper.In this case, a judge, rather than a jury, determined in 2004 that Appellant’s extended term sentence was necessary for the protection of the public, which was contrary to the Supreme Court’s holding in Flubacher v. State, 414 P.3d 161 (Haw. 2018). Therefore, the Court concluded that Appellant’s extended term sentence was imposed in an illegal manner. Therefore, the Supreme Court vacated in part the ICA’s judgment on appeal as to the extended term sentence, vacated in part the circuit court’s order as to the extended term sentence, and remanded this case for further proceedings. As to the other issues discussed in the ICA’s memorandum opinion and judgment on appeal were not before the Court, the Court did not disturb the ICA’s conclusions as to those other issues. View "Batalona v. State " on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the intermediate court of appeals (ICA) affirming the circuit court’s grant of summary judgment for Respondent as to all counts in Petitioner’s counterclaim in this property dispute.Respondent filed a complaint against Petitioner alleging that Petitioner had trespassed upon his property and destroyed his landscaping. Petitioner filed a counterclaim arguing that Respondent’s property had been dedicated for exclusive use as a cemetery and that Petitioner had the right to enter the property to visit a family burial site. Petitioner also requested a declaratory judgment clarifying the nature and extent of the parties’ rights and responsibilities with respect to the property. Petitioner also sought to quiet title. The circuit court granted Respondent’s motion for summary judgment as to all claims. The ICA affirmed. The Supreme Court remanded the case to the circuit court for further proceedings, holding that the ICA (1) did not err in affirming the summary judgment with respect to Petitioner’s statutory dedication claim and in holding that Petitioner was not entitled to relief under Haw. Rev. Stat. chapter 669; but (2) erred in concluding that the circuit court correctly granted summary judgment in favor of Respondent on Petitioner’s common law dedication claim. View "Ibbetson v. Kaiawe" on Justia Law

At issue was whether a certificate of title was entered when a deed was accepted by the Office of the Assistant Registrar of the Land Court and stamped with a new certificate of title number.Plaintiff-mortgagor brought this action against Defendant-purchaser arguing that the non-judicial foreclosure sale of certain property was not lawfully conducted. Defendant moved for summary judgment arguing that Plaintiff’s arguments to invalidate the foreclosure sale were untimely because they were not raised before the issuance of a new certificate of title. Plaintiff argued in response that a new certificate of title had not been issued, and therefore, Plaintiff was not prevented from challenging the non-judicial foreclosure. The circuit court granted summary judgment, concluding that the issuance of a new certificate of title number was sufficient to provide Defendant with statutory protection. The Supreme Court vacated the grant of summary judgment and remanded for further proceedings, holding (1) assignment of a new certificate of title number is not the statutory equivalent of an entry of a certificate of title, and therefore, the evidence in this case did not establish that a certificate of title had been entered; (2) accordingly, Plaintiff was not barred from bringing this action; and (3) an issue of material fact existed precluding summary judgment. View "Wells Fargo Bank, N.A. v. Omiya" on Justia Law

Haw. Rev. Stat. 386-8, which governs a third party’s liability for workers’ compensation, provides the exclusive remedy for an employer to recover workers’ compensation benefits from a third-party tortfeasor.An employee of Hawaiian Dredging Construction Company, Inc. (HDCC) was injured in a workplace accident, allegedly due to the actions of HDCC’s subcontractor, Fujikawa Associates, Inc. (Fujikawa). HDCC sought reimbursement from Fujikawa, claiming that workers’ compensation benefits were within the scope of the subcontract’s indemnity clause. When Fujikawa refused to indemnify HDCC, HDCC filed a complaint alleging breach of the subcontract. The circuit court granted summary judgment in favor of Fujikawa. The Supreme Court affirmed, holding that summary judgment was appropriate because HDCC did not avail itself of the exclusive remedy provided in section 386-8. View "Hawaiian Dredging Construction Co. v. Fujikawa Associates, Inc." on Justia Law

In this case regarding Petitioner’s request to access judicial records and documents related to a circuit court criminal proceeding, the Supreme Court ordered that the circuit court unseal the documents and that Petitioner be permitted to represent himself in any further proceedings on this matter.Petitioner filed a petition for writs of prohibition and mandamus to obtain access to sealed court documents and records. The petition further sought an order prohibiting the circuit court judge from requiring Petitioner to retain an attorney in order to assert a constitutional right of access to judicial records. The Supreme Court granted the petition, holding (1) the substantive requirements for sealing were not met because the record did not demonstrate a compelling need sufficient to overcome the public’s constitutional right of access; and (2) because Petitioner asserted the constitutional right of access as an individual, he had a right to represent himself in the unsealing proceedings. View "Grube v. Trader" on Justia Law

The Supreme Court vacated the judgment of the circuit court refusing to accept Tracy Souza’s offer to stipulate to his prior felony conviction, which constituted an element of an offense with which he was charged.Souza was charged by felony information with place to keep unloaded firearms other than pistols and revolvers and ownership or possession prohibited of any firearm or ammunition by a person convicted of certain crimes. Following jury selection, Souza stipulated to his prior felony conviction. The jury found Souza guilty of both charged offenses. On appeal, Souza maintained that he was forced to accept the State’s proposed stipulation, which contained facts that were not elements of the offense and were unduly prejudicial. The intermediate court of appeals (ICA) affirmed the circuit court’s judgment. The Supreme Court reversed, holding that the manner in which the circuit court addressed Souza’s offer to stipulate to the prior conviction element was inconsistent with this Court’s decision in State v. Murray, 169 P.3d 955 (Haw. 2007), and the error was not harmless beyond a reasonable doubt. View "State v. Souza" on Justia Law

The intermediate court of appeals (ICA) did not err in ruling that an injury suffered by Plaintiff that arose while she worked as a Public Health Educator IV for the State Department of Health (DOH) resulted from an “accident occurring while in the actual performance of duty at some definite time and place” and was therefore a covered injury under Haw. Rev. Stat. 88-336.Section 88-336 provides service-connected disability retirement benefits under the Employees’ Retirement System’s (ERS) Hybrid Plan to Class H public officers and employees, such as Petitioner. Petitioner submitted an application for service-connected disability retirement in connection with permanent incapacitating injuries she suffered to her elbow, arm, and hand. A hearing officer concluded that Petitioner’s excessive keyboarding over a period of time did not constitute an “accident” because it did not occur at a “specific time and place.” The ERS denied Petitioner’s application. The circuit court affirmed. The ICA vacated the circuit court’s decision and remanded to the circuit court with directions to vacate the ERS Board’s denial of disability retirement to Petitioner. The Supreme Court affirmed, holding that Petitioner’s injury occurred “while in the actual performance of duty at some definite time and place.” View "Pasco v. Board of Trustees of the Employees’ Retirement System" on Justia Law

The Supreme Court vacated Defendant’s convictions for unlawful imprisonment in the second degree and abuse of family or household members, holding that the prosecutor’s statements during closing argument amounted to an unwarranted attack on the person character of defense counsel and, by extension, Defendant, and the misconduct warranted vacating Defendant’s convictions.At issue on appeal was the propriety of the prosecutor’s remarks suggesting that opposing counsel attempted to induce the complaining witness to give false testimony during cross-examination. The intermediate court of appeals (ICA) affirmed the judgment, holding that there was no reasonable possibility that the prosecutor’s comment contributed to Defendant’s convictions. The Supreme Court reversed, holding (1) the nature of the prosecution’s remarks during closing argument, the lack of any effective curative instruction, and the relative weight of the evidence, considered collectively, made clear that there was a reasonable possibility that the error might have contributed to Defendant’s convictions; and (2) the improper remarks did not clearly deny Defendant a fair trial, and therefore, the protections of double jeopardy were not implicated. View "State v. Underwood" on Justia Law

The Supreme Court affirmed the circuit court’s grant of partial summary judgment to Plaintiff on remand from a decision by the intermediate court of appeals (ICA) in Plaintiff’s favor on two issues relating to the existence of an implied easement from a landlocked parcel of land to the nearest road.The ICA held (1) the “unity of ownership” element for an implied easement may be satisfied by the Kingdom of Hawaii’s ownership of the two parcels prior to severance; and (2) the statute of limitations in Haw. Rev. Stat. 657-31 does not apply to implied easements, as in this case, but only to easements by prescription. The Supreme Court affirmed the circuit court’s grant of summary judgment on each issue, holding that the ICA did not err in its judgment. View "Malulani Group, Ltd. v. Kaupo Ranch, LTD" on Justia Law