Justia Hawaii Supreme Court Opinion Summaries

Petitioner, the former State director of United Public Workers, AFSCME Local 646, FL-CIO (UPW) and a former administrator of UPW’s Mutual Aid Fund trust (MAF), was held liable by a federal district court for negligently making loans under ERISA and thus breaching his fiduciary duties to the MAF. The court entered judgment against Petitioner in the amount of $850,000. Petitioner filed a complaint in the circuit court requesting that UPW indemnify him for the $850,000 on the grounds that his liability to the MAF arose from actions he took solely in his capacity as agent for UPW and/or that UPW ratified his actions. The circuit court granted summary judgment for UPW. The Intermediate Court of Appeals (ICA) affirmed, concluding that because Petitioner was responsible for his own conduct, he was not entitled to be indemnified for his negligent acts as a matter of law. Petitioner requested certiorari, claiming that the ICA erred in concluding that his negligence claim defeated his indemnification claim as a matter of law. The Supreme Court denied certiorari without reaching this issue, holding that ERISA preemption, not Petitioner’s negligence, defeated Petitioner’s state indemnity claims against UPW as a matter of law. View "Rodrigues v. United Public Workers, AFSCME Local 646" on Justia Law

Appellants - State Representative Bob McDermott, Garret Hashimoto, William E.K. Kumia, and David Langdon - filed suit to invalidate the Hawai’i Marriage Equality Act of 2013, which changed Hawaii’s definition of marriage so that same-sex couples could marry. The circuit court upheld the Act’s validity and granted summary judgment for Appellees - the Governor and the Director of the Department of Health. Appellants appealed, arguing that the 2013 Act was unconstitutional under Haw. Const. art. I, 23, which provides that the “legislature shall have the power to reserve marriage to opposite-sex couples.” The Supreme Court vacated the circuit court’s order and remanded with instructions to dismiss the case for want of jurisdiction, holding that Appellants lacked standing to bring this lawsuit, as moral or ideological disapproval to same-sex marriage does not constitute a legally cognizable injury sufficient to establish standing. View "McDermott v. Ige" on Justia Law

While living at Mayor Wright Homes, a federally-subsidized Public housing project owned and operated by Hawai’i Public Housing Authority (HPHA), Fetu Kolio misappropriated approximately $1,400 in Mayor Wright Homes Tenant Association funds. HPHA evicted Kolio, asserting that Kolio’s theft of the funds violated a term in his lease that stated that a tenant shall not engage in any “criminal activity” that “threatens the health, safety, or right to peaceful enjoyment” of the housing premises. The circuit court and intermediate court of appeals affirmed the Eviction Board’s order. The Supreme Court reversed, holding (1) HPHA failed to carry its burden of showing that Kolio’s theft threatened the health, safety, or peaceful enjoyment of the premises; and (2) Kolio’s theft did not meet the definition of criminal activity given in Hawai’i Administrative Rules 17-2020. View "Kolio v. Hawaii Pub. Housing Auth." on Justia Law

Since 1993, Defendant claimed lawful ownership of a property that was fraudulently transferred to him as part of a conspiracy to prevent Plaintiffs from collecting on a judgment. After two remands, a third jury found that the transfer of certain property was fraudulent and awarded $253,000 in special damages and $1,642,857 in punitive damages. Defendant appealed, arguing that the punitive damages award was grossly excessive and in violation of his rights under the Fourteenth Amendment. The intermediate court of appeals (ICA) vacated the punitive damages award. The Supreme Court vacated the ICA’s judgment, holding that the punitive damages awarded by the third jury was justified and did not violate Defendant’s federal due process rights. View "Kekona v. Bornemann" on Justia Law

The Planning Director of the County of Hawaii approved the application of Michael Pruglo to consolidate and resubdivide the pre-existing lots on his forty-nine-acre parcel of land. Mark Kellberg, who owned land adjacent to the subject property, objected to the approval. Kellberg brought suit against the Planning Director and the County of Hawaii seeking to have the subdivision declared void. The intermediate court of appeals (ICA) ruled that the Planning Director’s approval of Pruglo’s subdivision was invalid because it increased the number of lots. The Supreme Court vacated the judgment of the ICA, holding that the ICA erred in ruling on the merits of Kellberg’s claims without addressing whether the owners of the lots within the subject property were required to be joined as parties under Haw. R. Civ. P. 19. Because the lot owners were necessary parties under Rule 19(a), the Court remanded the case to the circuit court with instructions to order the joinder of the lot owners under Rule 19. View "Kellberg v. Yuen" on Justia Law

After Defendants fell behind on their mortgage payments, their lender (“the Bank”) commenced a non-judicial foreclosure sale of the property, acquired the property at auction, and filed an ejectment action. The circuit court granted summary judgment for the Bank, judgment for possession, and a writ of possession (“the April 12th orders”). Defendants filed a motion to reconsider. Defendant later filed an amended Haw. R. Civ. P. 60(b) motion for relief from judgment. The circuit court denied Defendants’ motion to reconsider but did not dispose of the amended Rule 60(b) motion. Defendants appealed. The intermediate court of appeals (ICA) determined that the appeal from the April 12th orders and motion to reconsider was untimely and ruled that the appeal was premature with respect to the amended Rule 60(b) motion. The Supreme Court (1) vacated the portion of the ICA dismissal order concluding that it lacked appellate jurisdiction over the appeal of the April 12th orders and the motion to reconsider, holding that the ICA had appellate jurisdiction over this portion of the appeal; and (2) affirmed the portion of the ICA dismissal order dismissing any appeal of the amended Rule 60(b) motion, holding that the ICA lacked jurisdiction over this portion of the appeal. View "Deutsche Bank Nat’l Trust Co. v. Amasol" on Justia Law

After a jury trial, Petitioner was convicted of terroristic threatening in the second degree and kidnapping. The Intermediate Court of Appeals affirmed Petitioner’s conviction and sentence. The Supreme Court reversed, holding that the circuit court erred in (1) instructing the prosecutor to inform the jury during closing arguments that the complaining witness was unavailable because she was dead - a fact not in evidence - and the error was not harmless beyond a reasonable doubt; and (2) admitting the complaining witness’s preliminary hearing testimony at trial in violation of Petitioner’s right to confrontation, and the error was not harmless. Remanded for a new trial. View "State v. Nofoa" on Justia Law

C. Brewer and Company, Ltd. (C. Brewer) sold the Kaloko Dam to James Pflueger. The Dam subsequently collapsed, resulting in seven deaths and extensive property damage. Pflueger filed suit seeking damages and indemnification from C. Brewer for claims against him arising out of the Dam’s failure. C. Brewer filed a complaint against James River Insurance Company (James River) seeking a ruling regarding James River’s obligations under a commercial general liability policy issued to C. Brewer that was in effect at the time of the Dam's failure. The circuit court granted summary judgment for James River, concluding that a Designated Premises Endorsement (DPE) precluded coverage. The Intermediate Court of Appeals (ICA) concluded that the intent of the parties as to the DPE was ambiguous and thus remanded for a determination of the parties’ intent as to the DPE. The Supreme Court affirmed in part and vacated in part, holding that the circuit court erred in granting summary judgment for James River and that the ICA erred in concluding it was necessary to determine the parties’ intent as to the DPE, as the DPE did not limit liability to injury and damage occurring on the designated premises. Remanded. View "C. Brewer & Co. v. Indus. Indemnity Co. of Am." on Justia Law

Plaintiff filed a class action complaint alleging that Defendants violated Hawaii law by charging customers of certain hotels service charges without fully disclosing to customers that the charges were not entirely being distributed to non-managerial service employees. The circuit court granted summary judgment for Plaintiff on Plaintiff’s wage law claims and granted summary judgment for Defendants on the unfair methods of competition (UMOC) claim. Defendants appealed, and Plaintiff cross-appealed. The Supreme Court affirmed the grant of summary judgment as to the unpaid wages but vacated the circuit court’s order granting summary judgment for Defendants on the UMOC claim and remanded for further proceedings. Plaintiff then requested an award of attorneys’ fees and costs for the appeal and cross-appeal and an award of post judgment interest on the damages. The Supreme Court held (1) Plaintiff was entitled to attorneys’ fees for both the appeal and the cross-appeal, and Defendants were jointly and severally liable for the payment of Plaintiff’s attorneys’ fees and costs; and (2) post judgment interest was not appropriate under the circumstances of this case. View "Gurrobat v. HTH Corp." on Justia Law

The State Director of Taxation retroactively assessed ten online travel companies for unpaid general excise tax (GET) and transient accommodations tax (TAT) for periods beginning between 1999 and 2001 and continuing until 2011. The Director also assessed penalties. The online travel companies appealed the assessments. The tax court (1) ruled in favor of the Director with regard to the GET assessments; but (2) ruled in favor of the online travel companies with regard to the TAT assessments. The Supreme Court affirmed in part and vacated in part the judgment in regard to the GET assessments and penalties and affirmed in regard to the TAT assessments, holding (1) the GET apportioning provision was misapplied in this case; and (2) the TAT was not applicable to the online travel companies in the assessed transactions. Remanded. View "In re Tax Appeal of Travelocity.com, L.P." on Justia Law