Justia Hawaii Supreme Court Opinion Summaries

In a case before the Supreme Court of Hawaii, the defendant, Kumulipo Iwa Coyote Sylva, was charged with second-degree murder for killing Eduardo Alejandro Cerezo. Sylva admitted to the killing but asserted the affirmative defense of insanity. In a jury trial, three medical examiners testified regarding Sylva's mental state at the time of the killing. Two of the examiners opined that Sylva lacked capacity due to a mental disease, disorder, or defect, thus excluding criminal responsibility. However, parts of the testimony of one of these examiners were struck by the circuit court. Sylva was ultimately convicted of manslaughter based on extreme mental or emotional disturbance (EMED).The Supreme Court of Hawaii held that the circuit court erroneously struck parts of the examiner's testimony which should have been admitted to clarify his opinion under Hawai‘i Revised Statutes § 704-410(4). The court found that a reasonable juror could have believed the circuit court instructed them to disregard the examiner's entire answer explaining his opinion that Sylva lacked capacity under the legal standard for insanity. The error was not harmless beyond a reasonable doubt because Sylva's insanity defense turned largely on the medical examiners’ testimonies. Therefore, the court vacated the circuit court’s judgment, conviction, and sentence, as well as the Intermediate Court of Appeal’s judgment on appeal, and remanded the case to the circuit court for further proceedings. View "State v. Silva " on Justia Law

The Supreme Court of the State of Hawai'i affirmed the judgment of the Intermediate Court of Appeals upholding the conviction of Michael Pickell for operating a vehicle under the influence of an intoxicant. The case centered around the legality of a traffic stop initiated by a Maui County police officer who observed Pickell executing a U-turn at a highway intersection with left turn only markings and signage but no signage explicitly prohibiting U-turns. Pickell argued that in the absence of an express sign prohibiting U-turns, as required by Hawai'i Revised Statutes (HRS) § 291C-82(c), the officer lacked reasonable suspicion to make the traffic stop. The court held that the Maui County ordinance, which requires drivers to follow the directional movements exhibited on markings and signage at intersections, was neither preempted by HRS § 291C-82(c) nor in conflict with it. Therefore, the officer had reasonable suspicion to initiate the traffic stop based on a violation of the Maui County ordinance, and the motion to suppress evidence from the stop was properly denied. View "State v. Pickell" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) reinstating the jury's verdict and judgment for Tiare Franco's family (the Francos) after granting Sabio Reinhardt's motion to set aside the jury verdict and judgment, holding that the ICA erred.The Francos brought a wrongful death lawsuit against Reinhardt for negligently crashing a truck and killing Tiare. National Interstate Insurance Company (NIIC), the truck's insurer, filed a declaratory judgment action claiming it had no duty to defend and indemnify Reinhardt under the policy. The circuit court granted summary judgment for NIIC, and the Francos successfully appealed. Before the ICA resolved the declaratory action appeal, the circuit court held a jury trial, and the jury returned a verdict in favor of the Francos. Counsel for Reinhardt moved to set aside the jury's verdict. The trial court granted the Francos' ensuing motion to disqualify counsel and Reinhardt's motion to set aside the jury verdict and judgment. The ICA reinstated the jury's verdict and judgment, holding that Reinhardt's counsel lacked authority to act as his lawyer. The Supreme Court vacated the ICA's judgment and affirmed the circuit court's orders, holding that the circuit court correctly denied the Francos' motion to disqualify counsel and did not abuse its discretion by granting Reinhardt's motion to set aside. View "Franco v. Reinhardt" on Justia Law

The Supreme Court held that, under Hawai'i law, an insurer may not seek reimbursement from an insured for defending claims when an insurance policy contains no excess provision for retirement, and furthermore, a reservation of rights letter will not do.At issue was whether an insurer may seek equitable reimbursement from an insured for defense fees and costs when the relevant insurance policy contains not express provision for such reimbursement but the insurer agrees to defend the insured under a reservation of rights, including reimbursement of defense fees and costs. The Supreme Court answered the question in the negative, holding that an insurer may not recover defense costs for defended claims unless the insurance policy contains an express right to reimbursement. View "St. Paul Fire & Marine Insurance Co. v. Bodell Construction Co." on Justia Law

The Supreme Court affirmed the orders of the circuit court denying Defendants' motions to dismiss for lack of jurisdiction and for failure to state a claim in this action brought by the City and County of Honolulu and the Honolulu Board of Water Supply (collectively, Plaintiffs) against a number of oil and gas producers (collectively, Defendants), holding that there was no error.Plaintiffs sued Defendants alleging public nuisance, private nuisance, strict liability failure to warn, negligent failure to warn, and trespass. Specifically, Plaintiffs alleged that Defendants engaged in a deceptive promotion campaign and misled the public about the dangers and environmental impact of using their fossil fuel products. Defendants filed a motion to dismiss, arguing, among other things, that Plaintiffs' claims were preempted by the Clean Air Act (CAA). The Supreme Court denied the motions, holding (1) Defendants were subject to specific jurisdiction in Hawai'i; (2) the CAA displaced federal common law governing interstate pollution damages suit, and following displacement, federal common law did and does not preempt state law; and (3) the CAA did not preempt Plaintiffs' claims. View "City & County of Honolulu v. Sunoco LP" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of mandamus challenging the final approval of the settlement in the underlying class action against the State, holding that Petitioner had no right to compensation.In 1920, the federal government pledged land to native Hawaiian beneficiaries, and while Hawai'i held the homestead land in trust it breached its fiduciary duties. In the underlying class action, trust beneficiaries successfully sued the State for breach of its trustee responsibilities, and the State settled. The Supreme Court accepted a petition for a writ of mandamus, an appeal challenging final approval of the case's settlement, and held (1) because Petitioner was born beyond the statutory period to receive a payout from the settlement he had no right to compensation; and (2) because this decision ended Petitioner's appeal, the appeal before the intermediate court of appeals was moot. View "Rivera v. Honorable Cataldo" on Justia Law

The Supreme Court adopted conspiracy jurisdiction in this case in which three law firms petitioned the Court to order a judge to dismiss them from the underlying lawsuit, holding that the law firms demonstrated a "clear and indisputable right to the relief requested and a lack of other means to redress adequately the alleged wrong or to obtain he requested action."Plaintiffs sued certain cigarette manufacturers and retailers, bringing product liability, fraud, and conspiracy claims. Plaintiff also sued three law firms that counseled the tobacco companies, alleging two counts of conspiracy. The law firms each filed motions to dismiss under Haw. R. Civ. P. (HRCP) Rule 12(b)(2), claiming that Hawai'i courts lacked general and specific jurisdiction over them. The circuit court denied the motions to dismiss without making minimum contacts findings or undertaking any due process analysis. The law firms subsequently petitioned the Supreme Court for a writ of prohibition and, alternatively, for a writ of mandamus ordering dismissal for lack of jurisdiction. The Court adopted conspiracy jurisdiction and granted the law firms' writ of prohibition, holding that the circuit court clearly exercised jurisdiction beyond its authority, and there were no other means for the law firms to adequately address the alleged wrong or to obtain dismissal. View "Dickinson v. Kim" on Justia Law

The Supreme Court vacated the circuit court's judgment, conviction, and sentence related to sentencing in this case, holding that the circuit court erred by not articulating a clear and comprehensive rationale for each of Defendant's consecutive sentences.Pursuant to a plea agreement, Defendant pled no contest to three felony counts. The court sentenced Defendant to consecutive five-year terms on each count for a total of fifteen years. The intermediate court of appeals (ICA) affirmed, thus rejecting Defendant's jurisdictional and sentencing challenges. The Supreme Court vacated the ICA's judgment on appeal and the circuit court's judgment related to sentencing and otherwise affirmed, holding (1) if the State files a complaint in district court and that court lawfully commits the case to circuit court then the circuit court has jurisdiction; and (2) the circuit court did not provide adequate independent grounds to impose each consecutive sentence. View "State v. Bautista" on Justia Law

The Supreme Court vacated the orders of the family court refusing to set aside a default judgment it ordered in favor of Husband against Wife as a discovery sanction under Hawai'i Family Court Rule (HFCR) 37(b)(2), holding that the court erred in declining to set aside the default judgment under HFCR 60(b)(1) for excusable neglect and entering default as a discovery sanction.On appeal to the Supreme Court, Wife argued that the intermediate court of appeals erred in affirming the family court's denial of her timely-filed HFCR Rule 60(b)(1) motion because her neglect was excusable. The Supreme Court vacated the family court's judgment, holding (1) the family court inadequately warned Wife about the risk and consequences of neglect and that Wife did not engage in deliberate, willful conduct under the circumstances of this case; and (2) the family court erred by declining to set aside the default judgment for excusable neglect and by entering default as a discovery sanction. View "JK v. DK" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing this action brought by Academic Labor United (ALU) requesting declaratory judgments that graduate assistants were foreclosed from exercising the collective bargaining rights provided to public employees under Haw. Const. art. XIII, 2 and Haw. Rev. Stat. 89, holding that there was no error.ALU, which represented graduate student employees of the University of Hawaii who wish to engage in collective bargaining, brought this suit arguing that a pair of 1972 decisions of the Hawaii Public Employment Relations Board determined that graduate assistants were not "employees" under chapter 89 and were thus foreclosed from exercising collective bargaining rights. The circuit court dismissed the case on jurisdictional grounds. The Supreme Court affirmed, holding that because ALU had not invoked Hawaii Administrative Rules 12-42-9 to clarify whether its members are employees under chapter 89 and had not exhausted its administrative remedies, the circuit court did not have jurisdiction over ALU's action. View "Academic Labor United v. Bd. of Regents of the University of Haw." on Justia Law