Justia Hawaii Supreme Court Opinion Summaries

At issue in this case was a nonjudicial foreclosure on real property conducted pursuant to Haw. Rev. Stat. 667-5. The circuit court entered final judgment in favor of the Mounts, the purchasers of the real property through the nonjudicial foreclosure sale, and U.S. Bank National Association. The final judgment was entered against the personal representative of the decedent’s estate. The circuit court ruled that a nonjudicial foreclosure conducted pursuant to section 667-5 is exempt from the time limits for presentation of claims against a decedent’s estate and that U.S. Bank did not violate section 667-5(c)(1) by failing to provide former co-personal representative Sesha Lovelace with information she requested regarding the required funds to reinstate the loan (“reinstatement figures”). The Supreme Court vacated the circuit court’s final judgment, holding (1) a nonjudicial foreclosure conducted pursuant to section 667-5 is not exempt from the time limits under Haw. Rev. Stat. 560:3-803 for presentation of claims against a decedent’s estate; and (2) the nonjudicial foreclosure was conducted in violation of section 667-5(c)(1) when U.S. Bank failed to provide Lovelace with loan reinstatement figures, and this failure rendered the nonjudicial foreclosure sale voidable at the Estate’s election unless the Mounts were innocent purchasers for value. Remanded. View "Mount v. Apao" on Justia Law

Defendant was found guilty of robbery in the second degree, kidnapping as a class A felony, and kidnapping as a class B felony. The circuit court merged Count 1 - the robbery, a lesser grade class B felony - into Count 2 - one of the kidnappings, a higher grade class A felony. The Intermediate Court of Appeals (ICA) vacated the circuit court’s judgment of conviction and sentence as to Count 2 as a class A felony and remanded for entry of a judgment of conviction on Count 2 as a Class B felony and resentencing on Count 2, concluding that the circuit court erred in convicting Defendant of kidnapping as a class A felony on Count 2 because Defendant was entitled to the mitigating defense, which would have reduced the kidnapping to a class B felony. The Supreme Court vacated the ICA’s judgment, holding that the ICA erred in remanding the case for resentencing solely on the Count 2 kidnapping conviction because the kidnapping convictions merged into the robbery conviction. Remanded for the circuit court to reinstate Defendant’s conviction on Count 1 and to dismiss the convictions on Counts 2, 3, 4, and 5 and to resentence Defendant on Count 1 only based on the merger of Counts 2 through 5 into Count 1. View "State v. Deguair " on Justia Law

Defendant was charged with manslaughter, and the case went to trial. After deliberating, the jurors sent a note to the court expressing concern for their safety. The circuit court subsequently declared a mistrial based on manifest necessity due to the jurors’ concerns about their safety. Defendant filed a motion to dismiss, arguing (1) the circuit court erred in finding manifest necessity and declaring a mistrial, and (2) further prosecution was prohibited on double jeopardy grounds. The circuit court denied the motion, and the Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the presumption of prejudice was not overcome beyond a reasonable doubt, and therefore, the circuit court did not abuse its discretion in determining that manifest necessity existed for a mistrial; and (2) accordingly, the court properly denied Defendant’s motion to dismiss on double jeopardy grounds. View "State v. Gouveia" on Justia Law

After a jury trial, Defendant was convicted of methamphetamine trafficking in the second degree. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the judgment of conviction of the circuit court, holding (1) the State did not lay a proper foundation to introduce the results of a Fourier Transform Infrared Spectrometer (FTIR) test, and therefore, the circuit court abused its discretion by permitting a criminalist with the Honolulu Police Department to testify that the results of the test conclusively established that the substances police officers recovered from Defendant contained methamphetamine; and (2) the error was not harmless. View "State v. Subia" on Justia Law

Plaintiffs filed this class action suit individually and on behalf of employees (and their dependent-beneficiaries) who began working for the State or its political subdivisions before July 1, 2003 and who had accrued or will accrue a right to post-retirement health benefits as a retiree a retiree’s dependent. Plaintiffs alleged that the State, the City and County of Honolulu, and the Counties of Kaua’i, Maui, and Hawai’i impaired Plaintiffs’ accrued retirement health benefits in violation of Haw. Const. art. XVI, 2. Specifically, Plaintiffs claimed that the State and Counties violated their statutory rights under Haw. Rev. Stat. 87 by not providing retirees and their dependents with dental and medical benefits that were substantially equal to those provided to active workers and their dependents. After a lengthy procedural history, the Supreme Court held that Plaintiffs’ accrued retirement health benefits have been diminished or impaired in violation of article XVI, section 2. Remanded for further proceedings. View "Dannenberg v. State" on Justia Law

In this custody dispute regarding Son, Mother moved to modify custody terms contained in a divorce decree, alleging that circumstances had changed because Father planned to move Son to Arizona. The family court ultimately found that Mother failed to establish a material change in circumstance since Father’s relocation was contemplated at the time the decree was entered and that it was still in Son’s best interest to live with Father. The Intermediate Court of Appeals (ICA) affirmed, concluding that the family court properly excluded Mother’s proffered evidence of Father’s pre-decree domestic violence on relevance grounds because the evidence was not related to the material change in circumstances preliminarily found to exist by the family court. The Supreme Court reversed, holding that the family court erred in excluding the evidence of Father’s pre-decree domestic violence as, (1) in Waldecker v. O’Scanlon, the Court overruled several ICA cases that suggested that a material change in circumstances was required before a court can modify a custody order according to the best interests of the child; and (2) in order to determine Son’s actual best interests as mandated by Haw. Rev. Stat. 571-46, the family court was required to address the specific and direct allegations of domestic violence before making its custody determination. View "Tumaneng v. Tumaneng" on Justia Law

Defendant was charged with murder and assault. Defendant was found unfit to proceed due to mental disease or disorder, and the proceedings against him were suspended until further court order. Defendant was committed to the custody of the Director of Health. The Director then moved for a transfer of Defendant’s custody from the Hospital to the Department of Public Safety (DPS). The circuit court denied the motion, concluding that pending a ruling that he had regained fitness, as an unfit person, Defendant could not be transferred to the DPS. The day after the Director’s appeal, the circuit court found Defendant fit to proceed and committed him to the custody of the DPS. The Intermediate Court of Appeals (ICA) dismissed the Director’s appeal as moot, ruling that it lacked appellate jurisdiction to hear the appeal because custody of Defendant had already been transferred from the Director to the DPS and no exception to the mootness doctrine applied. The Supreme Court vacated the ICA’s order, holding that the ICA erred in not considering the “capable of repetition, yet evading review” exception to the mootness doctrine. Remanded. View "State v. Tui" on Justia Law

The Board of Land and Natural Resources (BLNR) granted a permit for the University of Hawaii to construct the Advanced Technology Solar Telescope at an area set aside for astronomical observations located within a conservation district near the summit of Haleakala on the island of Maui. Kilakila 'O Haleakala (Kilakila) challenged BLNR’s approval of the permit. Both the circuit court and the Intermediate Court of Appeals affirmed BLNR’s decision. The Supreme Court affirmed, holding (1) the permit approval process was not procedurally flawed by prejudgment or by impermissible ex parte communication; and (2) BLNR validly determined that the telescope met the applicable permit criteria and was consistent with the purposes of the conservation district. View "Kilakila 'O Haleakala v. Bd. of Land & Nat. Res." on Justia Law

At issue in this case was a proposed project for constructing a new telescope at an area set aside for astronomical research located within a conservation district near the summit of Haleakala on the island of Maui. The University of Hawaii (UH) prepared a Management Plan containing guidelines applying to facilities within the astronomical site area. UH found that the Management Plan would not have a significant environmental impact and, therefore, that an environmental impact statement was not required. Kilakila ‘O Haleakala (Kilakila) brought a court action to challenge UH’s finding. During discovery, Kilakila sought to obtain documents and admissions from UH and the Department of Land and Natural Resources (DLNR) relating to the environmental assessment. UH and DLNR sought a protective order regarding Kilakila’s discovery request, contending that judicial review was restricted to the administrative record. The circuit court granted the protective order. The Supreme Court affirmed, holding (1) while judicial review of the agency’s determination was not restricted to the administrative record, the circuit court did not err because the parties were permitted to submit documents beyond those contained within the agency record, and the court did not foreclose further discovery requests; and (2) UH’s conclusion that the Management Plan would not cause significant environmental impacts was not clearly erroneous. View "Kilakila 'O Haleakala v. Univ. of Hawaii" on Justia Law

After a jury trial, Defendant was convicted for the attempted murder of his wife. Defendant appealed, arguing that the circuit court violated his rights under the Fourth Amendment of the United States Constitution and Haw. Const. art. I, 7 by denying his motion to suppress. The Intermediate Court of Appeals vacated Defendant’s conviction, concluding that the circuit court erred in applying the plain view doctrine to the discovery of certain evidence. The Supreme Court reversed the ICA’s judgment on appeal and affirmed the trial court’s amended judgment of conviction, holding (1) the ICA adopted an interpretation of the plain view doctrine that is contrary to the Court’s prior decisions and the protections and limits of the rights guaranteed under Haw. Const. art. I, 7; and (2) the warrantless seizure of the evidence at issue was lawful. View "State v. Phillips" on Justia Law