Justia Hawaii Supreme Court Opinion Summaries

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

Certified Construction, Inc. (CCI) submitted a bid proposal on a public works project by the County of Hawaii. The County disqualified CCI’s bid on the basis that the project required a C-44 license. CCI filed a bid protest with the County, arguing that nothing in the bid solicitation strictly required a C-44 license. The Office of Administrative Hearings dismissed the protest as untimely, concluding that CCI’s protest was a challenge to the contents of the bid solicitation rather than to the disqualification of its bid proposal. The circuit court disagreed and remanded the case for further proceedings. On remand, the hearings officer determined that CCI failed to demonstrate entitlement to relief. The circuit court affirmed. CCI appealed from the circuit court’s second order, and the County appealed from the circuit court’s first order. The Intermediate Court of Appeals (ICA) concluded that CCI’s protest was untimely and that the OAH lacked jurisdiction to consider CCI’s protest. The Supreme Court vacated the ICA’s judgment on appeal, holding that the ICA erred in concluding that CCI’s bid protest challenged the contents of the County’s bid solicitation because the protest, in fact, challenged the County’s disqualification of CCI’s bid proposal. View "Certified Construction, Inc. v. Crawford" on Justia Law

This case stemmed from a divorce action by Husband against Wife. Husband tendered a settlement offer to Wife, but Wife did not agree to the offer. The case was tried, and the family court ultimately issued a divorce decree that divided the parties’ marital assets. Following an unsuccessful appeal by Wife, Husband moved for an award of post-offer attorney’s fees and costs pursuant to Hawaii Family Court Rules (HFCR) Rule 68. The family court granted the motion as to Husband’s post-offer trial fees and costs and denied the motion as to Husband’s appellate fees and costs. The Intermediate Court of Appeals (ICA) vacated the family court order, ruling that appellate fees are recoverable under Rule 68. The court remanded the case to the family court to determine whether an award of appellate fees to Husband would be inequitable pursuant to the provisions of Haw. Rev. Stat. 580-47. Husband appealed, arguing that he was entitled to appellate fees as a matter of law. The Supreme Court vacated the ICA’s judgment, holding (1) the 2006 and 2015 versions of HFCR Rule 68 do not apply to family court cases governed by Haw. Rev. Stat. 580-47; and (2) therefore, Husband is not entitled to appellate attorney’s fees under Rule 68. View "Cox v. Cox" on Justia Law

Defendant pleaded guilty to one count of murder in the second degree. Before he was sentenced, Defendant filed a motion to withdraw plea, arguing that his plea was not entered knowingly, intelligently, or voluntarily because he felt pressured by his public defender and interpreter to plead guilty. The circuit court denied the motion and sentenced Defendant to life imprisonment with the possibility of parole. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the circuit court’s judgment of conviction and sentence, holding that the circuit court abused its discretion in denying Defendant’s motion to withdraw his plea, as the record did not establish that Defendant knowingly, intelligently and voluntarily entered his plea with an understanding of the nature of the charge against him and the consequences of his plea. View "State v. Krstoth" on Justia Law

Appellant, a furloughee on extended furlough in the community, failed to check in with his case manager. The State charged Appellant with escape in the second degree, in violation of Haw. Rev. Stat. 710-1021. Section 710-1021 states that a person commits the offense of escape in the second degree if the person “intentionally escapes from a correctional or detention facility or from custody.” Appellant filed a motion to dismiss for failure to state an offense, arguing that the escape charge failed to define “custody,” an essential element of the offense. The circuit court denied the motion. After a trial, the jury found Appellant guilty as charged. The intermediate court of appeals affirmed. The Supreme Court reversed for insufficiency of the evidence, holding that, under the facts of this case, failure to check in while on extended furlough is not punishable as escape in the second degree. View "State v. Paris" on Justia Law

Defendant was found guilty of operating a vehicle without motor vehicle insurance in violation of Haw. Rev. Stat. 431:10C-104 and sentenced to a $500 fine. Defendant filed a notice of appeal and requested waiver of her transcript costs pursuant to Haw. Rev. Stat. 802-7. The Intermediate Court of Appeals (ICA) denied Defendant’s request for waiver, concluding that Defendant was not a “criminal defendant” as required by the statute. Defendant proceeded with her appeal, arguing that the district court erred by failing to adjudicate her case pursuant to Haw. Rev. Stat. Chapter 291D. The ICA affirmed, holding that Chapter 291D does not apply to violations of section 431:10C-104. The Supreme Court vacated the ICA’s judgment on appeal and remanded, holding (1) the ICA correctly determined that Chapter 291D did not apply to Defendant’s section 431:10C offense; but (2) the ICA erred in denying Defendant’s request for transcript costs under section 802-7 on the basis that she was not a criminal defendant. View "State v. Godines" on Justia Law

When Mother and Father divorced, a settlement agreement incorporated into the divorce decree provided that both parents would have joint physical custody of their child but if either parent moved more than two hundred miles away then sole custody would automatically revert to the remaining parent. Mother later filed a petition to change the custody arrangement arguing that her anticipated relocation constituted a material change in circumstances requiring the family court to examine whether the change of custody would be in their child’s best interests. The family court enforced the divorce decree and awarded sole physical custody of the child to Father without explicitly finding that the change of custody was in the child’s best interests, concluding that because the parties had contemplated a future relocation in the divorce decree, there was no material change in circumstances. The intermediate court of appeals affirmed. The Supreme Court vacated the lower courts’ judgments, holding that the family court erred in enforcing the divorce decree and awarding sole physical custody of the child to Father without considering the best interests of the child. Remanded. View "Waldecker v. O’Scanlon" on Justia Law

In 2010 and 2012, the Commission issued charges against William Boyd, a charter school employee, for alleged violations of Haw. Rev. Stat. 84-14 that occurred in 2006 and 2007. Boyd filed a motion to dismiss, arguing that the Commission lacked jurisdiction to adjudicate proceedings against him because he was not an employee of the State subject to the code of ethics contained in Haw. Rev. Stat. Chapter 84. The Commission denied Boyd’s motion and concluded that Boyd was an “employee” as defined in Haw. Rev. Stat. 84-3. The Commission then concluded that Boyd committed several violations of Chapter 84 and imposed a total administrative fine of $10,000. The circuit court affirmed the Commission’s determination that Boyd as an “employee” under section 84-3 and was thus subject to the code of ethics in Chapter 84. The Intermediate Court of Appeals (ICA) affirmed the determination. The Supreme Court vacated the lower courts’ judgments and the Commission’s decision and order, holding (1) in accordance with Haw. Rev. Stat. 302B-9(a), charter school employees were exempt from Haw. Rev. Stat. 84-14 at the relevant time period in this case; and (2) therefore, the Commission did not have the authority to adjudicate the proceedings against Boyd. View "Boyd v. Haw. State Ethics Comm’n" on Justia Law

The Green Party of Hawaii and seven registered voters who voted in the 2012 General Elections (collectively, Green Party) filed this action seeking a declaratory judgment that certain methodologies and procedures used by the Office of Elections in the 2012 election were invalid under the Hawaii Administrative Procedure Act (HAPA). The circuit court granted summary judgment in favor of the Office of Elections, concluding that the challenged procedures were not subject to HAPA rulemaking requirements. The Supreme Court vacated the circuit court’s judgment in part, holding that the procedures used to determine that there will be a sufficient number of ballots ordered for each precinct for a general or primary election and the policy for counting votes cast on ballots for the incorrect precinct are rules under HAPA and, therefore, are subject to HAPA’s rulemaking requirements. View "Green Party of Hawaii v. Nago" on Justia Law