Justia Hawaii Supreme Court Opinion Summaries

Plaintiff, a State of Hawaii employee, was injured in an accident on the premises of the University of Hawaii Leward Community College one hour after he ended work for the day. The State denied Plaintiff’s claim for compensation on the basis that his injury was not work related. The Labor and Industrial Relations Appeals Board (LIRAB) determined that the State had presented sufficient evidence to overcome the presumption that Plaintiff’s knee injury was a covered work-related injury. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment and the LIRAB’s decision and order, holding that the LIRAB erred in concluding that the State rebutted the presumption that Plaintiff’s knee injury was a compensable work injury. View "Yoshii v. State, Univ. of Hawaii" on Justia Law

This case arose out of a dispute over title to a parcel of land in Oahu. The ownership interests of Lesieli Teisina (Lesieli) and Peni Teisina (Peni), who held estates in common, were challenged by a co-owner of the property, Hovey Lambert, as the statutory period for adverse possession was ending. Lambert named Lesieli and other defendants but failed to name Peni. Lesieli and Peni, who later moved to intervene, asserted adverse possession as an affirmative defense. The circuit court concluded that Peni had no interest in the parcel and that Lesieli had only a minute interest in the parcel, thus implicitly rejecting the Teisinas’ adverse possession defense. The intermediate court of appeals (ICA) affirmed the circuit court’s denial of the Teisinas’ affirmative defense of adverse possession. The Supreme Court vacated in part, holding that the ICA erred in affirming that portion of the circuit court order that implicitly rejected Peni’s adverse possession defense, as (1) the facts of this case satisfy the evidentiary burden on summary judgment of demonstrating compliance with the good faith requirement required in cases involving adverse possession against cotenants; and (2) the statutory period for adverse possession tolls for a named party to the litigation but continues to accrue for unnamed claimants. View "Lambert v. Waha " on Justia Law

The City and County of of Honolulu provided refuse collection services through the use of front-end loader work crews to service 181 multi-unit residential properties and numerous City agencies. After the City decided to discontinue front loader collection services, United Public Workers (the Union) sued the City and County. The Union filed a motion for a preliminary injunction seeking to enjoin the City from unilaterally implementing the privatization of the collection and disposal services. The circuit court granted partial summary judgment to the Union and permanently enjoined the City from discontinuing the services at issue, concluding that the City and County’s cancellation of the services constituted impermissible privatization. The circuit court certified the partial summary judgment order for appeal and stayed the proceedings as to the remaining counts. The Supreme Court affirmed, holding (1) the City and County’s decision to terminate front loader refuse collection services violated constitutional merit principles and civil service laws and deprived the civil service workers in this case of the protections guaranteed in Article XVI, Section 1 of the Hawaii Constitution and Haw. Rev. Stat. 76 and 77; and (2) the circuit court did not err in granting partial summary judgment in favor of the Union as to the asserted violations of constitutional merit principles. View "Salera v. Caldwell" on Justia Law

Defendant, a farmer, was transporting cabbages in the back of his uncovered truck when some of the produce spilled out onto the road. The district court found Defendant guilty of violating Haw. Rev. Stat. 291C-131, which prohibits spilling loads on highways. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court reversed, holding (1) the ICA did not err in holding that Defendant was required to present evidence on every element of the defense before he met his burden of production; but (2) Defendant met his burden of production because “reasonable removal” under section 291C-131(c) requires removal of spilled agricultural produce only when the removal is reasonable, and the prosecution did not produce evidence disproving the elements of Defendant’s defense beyond a reasonable doubt. View "State v. Bowman" on Justia Law

After a jury trial, Defendant was convicted of three counts of sexual assault in the first degree and three counts of sexual assault in the third degree. Defendant appealed, arguing, among other things, that expert testimony regarding child sexual abuse is no longer relevant. The intermediate court of appeals (ICA) affirmed the judgment of conviction and sentence. The Supreme Court affirmed, holding (1) the trial court did not err in admitting the expert testimony regarding the unique characteristics of child sexual abuse victims to assist the jury in comprehending delayed reporting; and (2) although Defendant did not properly preserve for appeal his argument that the expert testimony presented in this case was unfairly prejudicial or misleading, the Court provided guidance in light of the ICA’s analysis of this issue. View "State v. Kony" on Justia Law

After Defendant performed surgery on Plaintiff’s back, Plaintiff filed a complaint alleging medical negligence and negligent failure to obtain informed consent. Defendant moved for summary judgment, alleging that he was entitled to judgment as a matter of law on Plaintiff’s claim of negligent failure to obtain informed consent because Plaintiff did not have medical expert testimony as to the “materiality” of the risk to support his claim. The circuit court agreed and granted summary judgment in favor of Defendant as to both of Plaintiff’s claims. The Supreme Court vacated the circuit court’s judgment as to the claim of negligent failure to obtain informed consent, holding (1) the common law materiality factors do not apply to a claim of negligent failure to obtain informed consent, and the circuit court erred in relying upon them instead of on Haw. Rev. Stat. 671-3(b); (2) consequently, Defendant was not entitled to judgment as a matter of law based on lack of expert testimony as to the common law materiality factors; and (3) the circuit court erred in concluding that Defendant was entitled to judgment as a matter of law on Plaintiff’s claim of negligent failure to obtain informed consent. View "Garcia v. Robinson" on Justia Law

Plaintiffs, Clarence Furuya and Lona Furuya, filed the underlying suit against Association of Apartment Owners of Pacific Monarch, Inc. (AOAO) raising issues related to their interests in an apartment unit located at the Pacific Monarch Condominium (Pacific Monarch) and 106 parking stalls appurtenant to the unit. The circuit court concluded that there was no enforceable contract between AOAO and the Furuyas for the purchase of the leased fee interests associated with the unit and the parking stalls. The Intermediate Court of Appeals (ICA) ultimately affirmed. The Supreme Court affirmed, holding (1) the Furuyas failed to demonstrate error in the circuit court’s decision; and (2) the circuit court did not err in rejecting the Furuyas’ related claims for injunctive relief, declaratory relief, and ultra vires act. View "Furuya v. Ass’n of Apartment Owners of Pacific Monarch, Inc." on Justia Law

Defendant was found guilty of operating a vehicle under the influence of an intoxicant (OVUII), in violation of Haw. Rev. Stat. 291E-61(a)(1) and/or (3). The Intermediate Court of Appeals (ICA) affirmed the judgment on appeal. The Supreme Court affirmed, holding (1) the district court did not err in permitting the State to amend Defendant’s section 291E-61(a)(1) charge to allege mens rea; and (2) insofar as the section 291E-61(a)(1) charge was properly amended and insofar as Defendant did not challenge the sufficiency of the evidence supporting his conviction for violating section 291E-61(a)(1), his OVUII conviction still stands, and there is no need to address Defendant’s argument that the breath test result supporting his section 291E-61(a)(3) conviction was obtained in violation of his constitutional rights. View "State v. Fisher " on Justia Law

Plaintiff, a Hawaii resident, filed an election contest complaint arguing (1) Presidential candidate Ted Cruz was not qualified to run for President of the United States and, therefore, the Republican Part was guilty of election fraud; (2) the Office of Elections sponsors racism by serving “whites only”; and (3) Governor David Ige is responsible for rampant bigotry and discrimination within the State. The State moved to dismiss the complaint. The Supreme Court entered judgment dismissing the complaint, holding that Plaintiff failed to demonstrate that the Supreme Court had jurisdiction over his complaint or the relief he sought. View "Smallwood v. State " on Justia Law

Defendant was arrested for operating a vehicle under the influence of an intoxicant (OVUII) and read an implied consent form. Defendant elected to take a breath test, which resulted in a breath alcohol content reading above the legal limit. Defendant moved to suppress the breath test result, arguing that his Fourth Amendment rights were violated. The district court denied the motion. Defendant was subsequently found guilty of OVUII. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA’s judgment on appeal and the district court’s judgment, holding that, in accordance with State v. Won, the result of Defendant’s breath test was the product of a warrantless search, and therefore, Defendant’s OVUII conviction could not be upheld. View "State v. Franco " on Justia Law