Justia Hawaii Supreme Court Opinion Summaries

Defendant was convicted of unauthorized entry into motor vehicle in the first degree. Before trial, the State filed a motion to determine the voluntariness of a statement Defendant made to the police. The circuit court granted in part and denied in part the State’s motion, finding that Defendant’s statement to a police officer that “I wouldn’t have to punch people if they didn’t upset me” was a voluntary statement and was admissible. The statement was made during the police officer’s “effort to make small talk and calm [Defendant] down.” The intermediate court of appeals affirmed, concluding that the absence of prior Miranda warnings by the police officer did not provide a basis to suppress Defendant’s “spontaneous and volunteered statement.” The Supreme Court reversed, holding (1) Defendant’s right against self-incrimination was violated because the police officer subjected Defendant, a person in custody pursuant to an arrest, to “interrogation” without the protection of a Miranda advisement; and (2) the circuit court abused its discretion in admitting evidence of 2006 prior bad acts. Remanded for a new trial. View "State v. Kazanas" on Justia Law

Plaintiffs - Pacific Radiation Oncology LLC (PRO) and several doctors - sued Queens Medical Center (QMC), which provided radiation oncology therapy services to patients of PRO using equipment and services provided by QMC, after QMC notified Plaintiffs that only physicians employed by QMC could provide professional radiation oncology services at QMC. QMC counterclaimed, alleging that Plaintiffs steered cancer patients away from QMC in violation of unfair competition principles. During litigation, QMC’s law firm publicly filed a list naming 132 patients PRO was alleged to have diverted. The patients were not parties to the underlying lawsuit, but nineteen of them were granted intervenor status. Plaintiffs moved for a temporary restraining order or preliminary injunction to prevent further violations of patient privacy. The magistrate judge found the 132 cancer patients’ confidential medical records to be relevant to the parties’ claims and counterclaims. On appeal, the district court certified questions to the Supreme Court. The Supreme Court answered (1) pursuant to Haw. Const. art. I, 6 the parties cannot use or be compelled to produce confidential patient medical records, even if sufficiently de-identified, in litigation where the patient is not a party; and (2) that provision protects the health information of the patient intervenors to this case. View "Pacific Radiation Oncology, LLC v. Queen’s Med. Ctr." on Justia Law

Civil Beat requested the disciplinary records of twelve Honolulu Police Department (HPD) officers who were suspended for various types of misconduct. HPD denied the request in its entirety. Civil Beat then filed a complaint seeking an order directing HPD to disclose the information Civil Beat sought. The circuit court ruled in favor of Civil Beat, concluding that police officers have a “non-existent” privacy interest in their disciplinary suspension records. The Supreme Court vacated the circuit court’s judgment, holding that police officers have a significant privacy interest in their disciplinary suspension records, and disclosure of the records is appropriate when the public interest in access to the records outweighs this privacy interest. Remanded for a determination of whether the public interest outweighs the officers’ significant privacy interests. View "Peer News LLC v. City & County of Honolulu" on Justia Law

Plaintiff, a former employee of the State, Department of the Attorney General, filed a workers’ compensation claim after he was diagnosed with depression and was later terminated. The sole question before the Labor and Industrial Relations Appeals Board (LIRAB) was whether Plaintiff sustained a personal psychological injury arising out of and in the course of employment. LIRAB found that Plaintiff’s psychological injury was attributed to a “Notice to Improve Performance" (NTIP) issued by his employer. The Intermediate Court of Appeals (ICA) affirmed, concluding that Plaintiff’s injury resulted solely from “disciplinary action,” and therefore, Plaintiff’s workers’ compensation claim was barred by Haw. Rev. Stat. 386-3(c). The Supreme Court vacated the ICA’s judgment, holding (1) Plaintiff’s NTIP was not “disciplinary action,” as that term is defined by Haw. Rev. Stat. 386-1 and 386-3; and (2) therefore, Plaintiff’s workers’ compensation claim is not barred by section 386-3(c). Remanded to LIRAB for further proceedings. View "Gao v. State" on Justia Law

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