Justia Hawaii Supreme Court Opinion Summaries

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The Supreme Court overruled Maha-ulepu v. Land Use Commission, 790 P.2d 906 (1990), superseded by statute, 2005 Haw.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

In this foreclosure proceeding, the Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's order granting Deutsche Bank's motion for summary judgment on its complaint to foreclose a mortgage, holding that Deutsche Bank did not establish that it had standing to foreclose.In 2006, Blaine Yata executed a note and mortgage to New Century Mortgage Corporation. The mortgage was later assigned to Deutsche Bank National Trust Company, as trustee for Morgan Stanley ABS Capital I Inc. Trust 2006-NC4 (Deutsche Bank). When Yata defaulted on the note, Deutsche Bank brought a complaint to foreclose on the mortgage. The circuit court granted summary judgment for Deutsche Bank. The ICA affirmed. The Supreme Court vacated the ICA's judgment on appeal, holding (1) the ICA misapplied U.S. Bank Trust, N.A. v Verhagen, 489 P.3d at 419 (2021) in determining that Deutsche Bank's documents were admissible; and (2) even if the documents were admissible, they would not establish that Deutsche Bank had possession of the note when it filed the complaint. View "Deutsche Bank National Trust Co. v. Yata" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) determining that Hawai'i law did not require the joinder of Defendant's traffic offenses with his assault offense, holding that the ICA did not err.Defendant was charged with two separate sets of offenses - traffic offenses and an assault offense - that he argued arose from a single criminal episode. Defendant filed a motion to dismiss, arguing that Haw. Rev. Stat. 701-109 required the State to try the traffic offenses and the assault offense together. The circuit court granted the motion to dismiss. The ICA vacated the circuit court's order, holding that the traffic offenses and the assault offense were not so closely related in time, place, or circumstances that section 701-109(2) compelled the joinder of the two proceedings. The Supreme Court affirmed, holding that Hawai'i law did not require joinder under the circumstances. View "State v. Sardinha" on Justia Law

The Supreme Court answered two questions of law certified by the United States Bankruptcy Court for the District of Hawai'i concerning a putative class action alleging wrongful foreclosure.Specifically, the Court answered (1) an action alleging a wrongful nonjudicial foreclosure of land court property that seeks only damages against the foreclosing lender is not barred by the entry of a transfer certificate of title to a buyer at a foreclosure sale; and (2) the pendency of a putative class action tolls the time during which a class member may commence an individual action, and the time for commencing an individual action is tolled until a clear denial of class certification. View "Yanagi v. Bank of America" on Justia Law

The Supreme Court vacated the order of the intermediate court of appeals (ICA) dismissing Appellant's appeal in this workers' compensation case for lack of a final, appealable order, holding that the ICA erred when it dismissed this appeal for lack of jurisdiction.These consolidated cases consisted of the decision of the Director of the Department of Labor and Industrial Relations (DCD) determining that Appellant sustained compensable work-related injuries but denying her claim for compensation relating to her alleged neck injury and sleep disorder. Following years of proceedings before the Labor and Industrial Relations Appeals Board (LIRAB) and DCD, the LIRAB issued several orders, including an order granting Employer/Insurer's two motions to compel and denying Appellant's motion for partial summary judgment. The ICA dismissed Appellant's appeal. The Supreme Court reversed, holding that the ICA had jurisdiction to review the LIRAB's order granting the motions to compel and denying partial summary judgment as to the order compelling Appellant to undergo an independent medical examination. View "Suzuki v. American Healthways, Inc." on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of murder in the second degree and the imposition of two consecutive life sentences without the possibility of parole, holding that Defendant was not entitled to relief on his allegations of error.Answering special verdict forms, the jury found that Defendant committed one of the two murders as a principal and accomplice and the other murder as an accomplice. During sentencing, the trial court enhanced each of Defendant's prison terms beyond the ordinary statutory maximum and ran those sentences consecutively. The Supreme Court affirmed, holding (1) the jury's verdict was not irreconcilably inconsistent; and (2) the trial court did not unlawfully enhance Defendant's two second-degree murder prison terms. View "State v. Perry" on Justia Law

The Supreme Court affirmed the decision of the intermediate court of appeals (ICA) affirming the judgment of the district court ruling on a Haw. Rev. Stat. 604-10.5 petition to enjoin harassment (injunction petition) after ninety days elapsed from issuance of an ex parte temporary restraining order (TRO), holding that the ICA correctly held the district court had subject matter jurisdiction in this case.Further at issue before the Supreme Court, other than the jurisdictional matter, was whether a section 604-10.5 TRO expires after ninety days despite orders by the district court continuing the TRO beyond ninety days pending completion of a hearing and decision on the injunction petition. The Supreme Court held that if a district court has commenced hearing the merits of a section 604-10.5 injunction petition but, despite reasonable efforts, is unable to conclude the hearing within ninety days of the issuance of the ex parte TRO, the court has jurisdiction to continue the TRO pending its final decision on the injunction petition. View "Meyer v. Basco" on Justia Law

The Supreme Court reversed the decisions of the lower courts affirming the ruling of the Honolulu Police Commission that Louis Kealoha, Chief of Police for the Honolulu Police Department (HPD), was entitled to a defense attorney provided by the City and County of Honolulu to defend him against federal criminal charges, holding that Kealoha did not meet his burden of establishing entitlement to representation.The Commission concluded that four acts alleged in the first superseding indictment against Kealoha entitled Kealoha to representation because they were done in the performance of Kealoha's duty as a police officer, even if the acts were unlawful and regardless of motive. The circuit court and intermediate court of appeals affirmed. The Supreme Court reversed, holding that because nothing in the record indicated that Kealoha was acting to perform his duties as Chief of Police during the conduct at issue, he was not entitled to taxpayer-funded representation. View "City & County of Honolulu v. Honolulu Police Comm'n" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the order of the circuit court granting the motion for summary judgment filed by the Hawai'i Criminal Justice Data Center (HCJDC) and dismissing Phillip Barker's action seeking to require the HCJDC to expunge his arrest record, holding that the ICA gravely erred.Barker, who was convicted of disorderly conduct as a violation, applied for expungement of his arrest, asserting that because Haw. Rev. Stat. 701-107(7) provides that a violation does not constitute a crime, he was entitled to expungement pursuant to Haw. Rev. Stat. 831-3.2. The HCJDC denied the application, concluding that Barker had been convicted of a "crime" within the meaning of section 831-3.2(a). The circuit court denied Barker's request for an order requiring the HCJDC to expunge his arrest record. The ICA affirmed. The Supreme Court vacated the judgments below, holding that under the plain language of Haw. Rev. Stat. 701-107(7) and §§ 831-3.2(a), a person arrested for or charged with a crime, including a petty misdemeanor, but convicted of a violation is eligible for expungement because a “violation” is not a “crime.” View "Barker v. Young" on Justia Law