Justia Hawaii Supreme Court Opinion Summaries

Petitioner was convicted for sex trafficking related crimes based on his conduct as a pimp for the complaining witness. Petitioner was present for voir dire and jury selection but failed to appear in court two days later despite instructions to do so. The trial was twice continued. After the second continuation, which lasted twenty-one days, the circuit court conducted trial in absentia. The intermediate court of Appeals (ICA) affirmed Petitioner’s conviction. The Supreme Court affirmed, holding (1) trial counsel did not provide ineffective assistance for failing to object to disjunctive charging language in jury instructions; and (2) the trial court did not violate Rule 43 of the Hawai’i Rules of Penal Procedure or violate Defendant’s right to be present at trial by proceeding with trial despite Defendant’s absence. View "State v. Vaimili" on Justia Law

This case arose from a dispute over a flag lot parcel of land in Puko’o, located on the Island of Moloka’i, County of Maui, State of Hawaii. At issue before the Supreme Court was whether an order deciding a motion that was purportedly filed pursuant to Haw. R. Civ. P. 60(b) is appealable where the underlying ruling from which the party sought Rule 60(b) relief was not appealable. The Intermediate Court of Appeals (ICA) dismissed the appeal for lack of appellate jurisdiction, concluding that the order regarding the Rule 60(b) motion was not appealable because the circuit court had not entered a valid final judgment on the underlying claims at issue. The Supreme Court affirmed, holding that relief under Rule 60(b) requires an underlying judgment that comports with the principles of finality set forth in Jenkins v. Cades Schutte Fleming & Wright, and therefore, the ICA did not err in including that it lacked appellate jurisdiction to review the order regarding the Rule 60(b) motion. View "Bailey v. Duvauchelle" on Justia Law

The Department of Transportation Airport Division (DOT-A), which leases Dillingham Airfield on the island of O’ahu from the United States Army, imposed landing fees on commercial users, including Petitioners. In 2012, DOT-A asserted that Petitioners owed DOT-A $264,995 in unpaid landing fees. Petitioners filed a complaint seeking the following relief: the return of landing fees paid under protest; injunctive relief preventing DOT-A from imposing additional fees against Petitioners; and a declaration that an administrative rule of DOT-A was invalid to the extent it established the rate of landing fees at the airfield. The circuit court denied injunctive relief and entered judgment on the merits in favor of DOT-A. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed, holding that DOT-A is not precluded from setting and imposing landing fees at the airfield through a DOT-A procedure that references the Hawaii Administrative Rules for the landing fee rates. View "Pofolk Aviation Haw., Inc. v. Dep’t of Transp. for State of Haw." on Justia Law

Plaintiff filed a complaint against Defendant in a state district court and later moved to dismiss the case. The district court granted the motion to dismiss without prejudice and awarded Defendant attorney’s fees pursuant to Hawai’i District Rules of Civil Procedure 41(a)(2), which grants a trial court discretion to impose attorney’s fees as a term or condition of voluntary dismissal. Plaintiff appealed, arguing that the district court erred in granting attorney’s fees before the merits of the case had been decided and before a prevailing party was properly identified. The intermediate court of appeals (ICA) affirmed, concluding that the district court did not err in awarding Defendant attorney’s fees in order to alleviate any prejudice resulting from the dismissal. The Supreme Court vacated the lower courts’ judgments and the award of attorney’s fees and costs, holding that the district court abused its discretion by (1) not providing Plaintiff with an opportunity to choose between accepting this condition or withdrawing her motion to dismiss; and (2) failing to evaluate and make findings on whether the award and amount of attorney’s fees and costs accords substantial justice to both parties. View "Tagupa v. VIPDesk" on Justia Law

Plaintiff, the excess insurer, and Defendant, the primary insurer, issued insurance policies to a travel service company. The company was sued for damages resulting from an accidental death. The case was settled in an amount in excess of Defendant’s policy limit. Plaintiff filed a complaint against Defendant, alleging that Defendant acted in bad faith by rejecting multiple settlement offers within the limit of its primary liability policy. Defendant moved for judgment on the pleadings, arguing that Plaintiff lacked standing to assert a claim for insurer bad faith and that Plaintiff had no claim against Defendant for equitable subrogation. The federal district court certified a question to the Hawaii Supreme Court. The Supreme Court held that an excess liability insurer can bring a cause of action under the doctrine of equitable subrogation against a primary liability insurer who, in bad faith, fails to settle a claim within the limits of the primary liability policy when the primary insurer has paid its policy limit toward settlement. View "St. Paul Fire & Marine Ins. Co. v. Liberty Mut. Ins. Co." on Justia Law

After the County of Kaua’i and Kaua’i Police Department filled five police sergeant positions through internal promotions, the State of Hawaii Organization of Police Officers (SHOPO) challenged, through the grievance procedures of the collective bargaining agreement (CBA) governing the parties, the non-promotions of three police officers. The parties were unable to resolve the grievances, and the matter was submitted to arbitration. The arbitrator found that the promotions were subjective, arbitrary, and capricious in violation of the CBA and awarded the three officers promotions and back pay. The circuit court vacated the arbitrator’s remedy, concluding that it was beyond the scope of the arbitrator’s authority to award promotions. The intermediate court of appeals (ICA) vacated in part the circuit court’s orders and remanded to the circuit court for confirmation of the arbitrator’s decision in its entirety, concluding that the arbitrator did not exceed his authority in awarding promotions and that the circuit court erred in finding otherwise. The Supreme Court affirmed, holding that the arbitrator acted within the scope of his authority under the CBA. View "In re Grievance Arbitration Between State of Haw. Org. of Police Officers" on Justia Law

Passed by voter initiative, the “Lowest Law Enforcement Priority of Cannabis” (LLEP) of the Hawai’i County Code provides that the cultivation, possession and use for adult personal use of cannabis shall be the lowest law enforcement priority for law enforcement agencies in the county. Petitioners, a group of pro se individuals, filed a complaint alleging that Defendants - members of the Hawai’i County Council, Hawai’i County prosecutors, and chief of police - failed to comply with the LLEP. The circuit court granted Defendants’ motions for judgment on the pleadings and dismissed the case, concluding that the LLEP was preempted by state law. The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the LLEP is preempted solely because it conflicts with state law; and (2) the entire LLEP is invalidated because it conflicts with, and is therefore preempted by, state law. View "Ruggles v. Yagong" on Justia Law

After a jury trial, Defendant was found guilty of theft of the proceeds of sale of the home of an individual for whom she was acting as a caregiver, changing the name of ownership of two joint accounts, and taking $8,000 from the joint account to pay off Chin’s car. Defendant filed a motion for a new trial, arguing that the actions of a jury foreperson in communicating with a main defense witness about possible employment was highly prejudicial. The circuit court denied the motion, concluding that the nature of the alleged deprivation did not rise to the level of being substantially prejudicial. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment on appeal and the judgment of conviction and sentence, holding (1) in this case, the circuit court was required to investigate the circumstances surrounding the nontrivial communication between the defense witness and the juror; and (2) because the circuit court did not conduct such an investigation, it could not be said that Defendant’s fundamental right to a fair trial by an impartial jury was not compromised. Remanded for a new trial. View "State v. Chin" on Justia Law

John Doe, a registered sex offender in the State of Washington, intended to vacation in Hawaii with his family. The Hawaii Criminal Justice Data Center (HCJDC) informed Doe that his Washington conviction was a covered offense requiring registration in Hawaii under Haw. Rev. Stat. 846E-2. Doe wrote to the Attorney General, seeking a “declaration” as to whether he was required to register as a sex offender while present in Hawaii. HCJDC replied on behalf of the Attorney General again informing Doe that he would be required to register in Hawaii. Doe filed a notice of appeal to the circuit court with respect to the decision of the Attorney General. The circuit court dismissed the case for lack of subject matter jurisdiction, concluding that Doe’s communications with HCJDC did not present a contested proceeding that was appealable. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court vacated the ICA’s affirmance of the circuit court’s dismissal of Doe’s agency appeal based on lack of jurisdiction, holding that a reasonable interpretation of HCJDC’s initial letter is as a denial of Doe’s petition for a declaratory order, thus affording Doe his right to appeal that decision to circuit court. View "Lawson v. Attorney General" on Justia Law

After a jury trial, Defendant was found guilty of assault in the first degree and sentenced to ten years in prison. Defendant appealed, arguing that the circuit court abused its discretion in denying his motion to substitute retained counsel in place of his court-appointed counsel. The intermediate appellate court (ICA) affirmed the conviction and sentence, concluding that the circuit court did not abuse its discretion in denying Defendant’s motion. 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 for withdrawal and substitution of counsel, resulting in the denial of Defendant’s right to privately retained counsel of choice under Haw. Const. art. I, 14. Remanded for a new trial. View "State v. Reed" on Justia Law