Justia Hawaii Supreme Court Opinion Summaries

Defendant pleaded no contest to continuous sexual assault of a minor under the age of fourteen and abuse of a family or household member. The family court accepted the plea agreement, found Defendant guilty as charged, and ordered the preparation of a pre-sentence investigation (PSI) report. Before sentencing, the prosecutor submitted a letter and three exhibits to the probation office for inclusion in Defendant’s PSI report that included recommendations relevant to sentencing. The submission would have been forwarded to the Hawaii Paroling Authority for its consideration at the minimum term hearing. Defendant moved to withdraw his no contest plea, arguing that the prosecutor’s submission constituted a breach of the plea agreement. The family court denied the motion. The Supreme Court vacated the family court’s findings and order, holding that the prosecutor’s submission of the letter and exhibits was a fair and just reason for Defendant’s withdrawal of his plea, and the State did not satisfy its burden to demonstrate substantial prejudice if the motion to withdraw the plea was granted. Remanded. View "State v. Garcia" on Justia Law

John Varel, the owner of a 1,000-acre parcel of property, filed a petition for injunction against harassment directed against Defendant. The circuit court granted the petition and entered an injunction order prohibiting Defendant from entering Varel’s “residence, including yard and garage.” When Defendant was discovered dirt biking on the outer limits of Varel’s property, he was charged with violating the injunction order. The district court concluded that Defendant violated the injunction order. Defendant appealed, arguing that the most reasonable construction of the term “yard,” as used in the injunction order, should not encompass the entire 1,000 acres of Varel’s property. The Intermediate Court of appeals affirmed. The Supreme Court reversed, holding (1) the meaning of “residence, including yard” encompasses only the house where Varel lives and the area directly adjacent to it, and therefore, the area of Varel’s property where Defendant was observed was outside the meaning of “residence, including yard”; and (2) accordingly, the conviction in this case was not supported by sufficient evidence and must be reversed. View "State v. Guyton" on Justia Law

Susan Gordon filed a complaint for divorce against Ira Gordon. The family court entered a divorce decree diving the parties’ property and awarding Susan alimony. The intermediate court of appeals (ICA) vacated the decree as it pertained to the property division and otherwise affirmed, holding that the family court was able to identify and value marital assets without a property division chart but erred by distributing a property to Ira that was no longer in the parties’ possession at the time of the divorce. The Supreme Court affirmed the ICA’s judgment to the extent that it vacated the family court’s decree and otherwise vacated the ICA’s judgment on appeal and the family court’s divorce decree, holding that the family court (1) erred in failing to support its property division with sufficient documentation so that the parties and reviewing court could ensure the division was equitable and free from miscalculations or other errors; (2) erred in deviating from a fifty-fifty division of the martial estate in addition to a deduction for marital waste; and (3) erred in its award of alimony to Susan. View "Gordon v. Gordon" on Justia Law

Plaintiffs, individual condominium owners, entered into purchase agreements with the developer of a Maui condominium project. Homeowners received the condominium declaration, which contained an arbitration clause, and other documents governing the project along with their purchase agreements. When the condominium development began experiencing financial problems, Homeowners filed suit against Respondents, the development and management companies for the project. Respondents filed a motion to compel arbitration, which the circuit court summarily denied. The intermediate court of appeals (ICA) reversed, holding that a valid arbitration agreement existed, this dispute fell within the scope of that agreement, the arbitration terms were procedurally conscionable, and the arbitration clause was not an unenforceable contract of adhesion. The Supreme Court vacated the ICA’s judgment and affirmed the circuit court’s order denying Respondents’ motion to compel arbitration, holding (1) because Plaintiffs did not unambiguously assent to arbitration, the agreement to arbitrate was unenforceable; (2) the ICA erred by placing dispositive weight on procedural unconscionability without addressing the alleged substantive unconscionability of the arbitration terms; and (3) the ICA erred by concluding that Plaintiffs had failed to demonstrate procedural unconscionability. View "Narayan v. Ritz-Carlton Dev. Co." on Justia Law

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