Justia Hawaii Supreme Court Opinion Summaries

In 1994, Investors Equity Life Insurance Company of Hawaii, Ltd. (IEL) was liquidated. The State Insurance Commission was appointed as IEL’s liquidator (Liquidator). In 1996, Investors Equity Life Holding Company (IELHC), the former parent company and sole shareholder of IEL, surrendered all of its shares in IEL to the Commissioner as part of a settlement agreement to resolve claims relating to IEL’s insolvency. The Liquidator proceeded to administer IEL’s estate. In 2008, IELHC wrote to the Liquidator claiming that it held legal or equitable title to all of IEL’s stock and demanding that the Liquidator turn over to IELHC all shares and assets remaining in IEL’s estate. The Liquidator denied the claim. The circuit court affirmed. The Supreme Court affirmed, holding (1) the circuit court did not err in concluding that IELHC asserted a claim against IEL’s estate and that the claim was time barred; (2) the circuit court had subject matter jurisdiction over IELHC’s claim and personal jurisdiction over IELHC; (3) there were no grounds for abating the adjudication of IELHC’s claim; and (4) the circuit court’s procedures met due process requirements. View "Ito v. Investors Equity Life Holding Co." on Justia Law

Plaintiff applied for a position with CDM Media, USA, Inc. Plaintiff was not hired for the position. Thereafter, Plaintiff filed a complaint alleging that CDM had decided not to hire her because of her age, and therefore, she had been subjected to employment discrimination. The circuit court granted summary judgment for CDM, concluding that Plaintiff had failed to demonstrate that CDM’s reasons for not hiring her were pretextual. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court vacated the judgments of the lower courts, holding that the trial court erred in granting summary judgment, as CDM did not satisfy its burden to produce a legitimate, nondiscriminatory reason for declining to hire Plaintiff. View "Adams v. CDM Media USA, Inc." on Justia Law

Defendant was indicted in counts I and III upon the charge of electronic enticement of a child in the first degree in violation of Haw. Rev. Stat. 707-756. Defendant moved to dismiss counts I and III, arguing that section 707-756 violates the dormant commerce clause and that the statute is unconstitutionally overbroad and vague. The trial court denied the motions to dismiss. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) based upon the plain language of section 707-756, its legislative history, and principles of statutory construction, the felonious intent of the statute applies only to the agreement element of that statute; and (2) the statute is not unconstitutionally overbroad or vague, and its application does not violate the dormant commerce clause. View "State v. Alangcas" on Justia Law

This labor dispute arose out of a negotiation between the State and other governmental entities (collectively, the State) and United Public Workers (UPW) regarding the renewal and modification of a collective bargaining agreement. The State and UPW failed to reach an agreement, and the case proceeded to arbitration. Because the parties were unable to select a neutral arbitrator, the Hawai’i Labor Relations Board (HLRB) ordered the American Arbitration Association to select the neutral arbitrator. Both parties challenged the actions of the HLRB. The circuit court affirmed the HLRB’s rulings. On appeal, UPW asserted that the circuit court had jurisdiction to resolve the dispute regarding the selection of the arbitrator. The Intermediate Court of Appeals disagreed, determining that HLRB had exclusive original jurisdiction under Haw. Rev. Stat. 89-14. UPW appealed, arguing that the circuit court had jurisdiction over the dispute regarding selection of the arbitrator under Haw. Rev. Stat. 658A. The Supreme Court affirmed, holding (1) the HLRB had jurisdiction to resolve the dispute over the selection of the arbitrator under chapter 89, as the arbitration was required by statute as part of the legislatively mandated process for resolving impasses in collective bargaining; and (2) chapter 658A was not applicable to this case. View "State v. Nakaneula" on Justia Law

In 2001, Petitioner was convicted of possession with intent to distribute crystal methamphetamine. Petitioner was released in 2003 and began a radiological technician (radtech) degree program. In 2007, after graduating from the program, Petitioner applied for a vacant radtech position at Hawai’i Health Systems Corporation (HHSC), d/b/a Hilo Medical Center (HMC) (collectively, HHSC/HMC). HHSC/HMC rejected Petitioner’s application because of his prior drug conviction. Petitioner filed suit, alleging violations of Haw. Rev. Stat. 378-2 and Haw. Const. art. I, 5. The circuit court granted summary judgment for HHSC/HMC. The Supreme Court reversed, holding that the circuit court erred in granting summary judgment where HHSC/HMC did not establish the existence of a rational relationship between the radtech possession and Petitioner’s prior drug conviction that would entitle HHSC/HMC to summary judgment. View "Shimose v. Haw. Health Sys. Corp." on Justia Law

Plaintiff filed a complaint contesting the second special election for councilmember for District IV, City and County of Honolulu, alleging errors in the counting of the votes and the handling of the ballots. Plaintiff, a nonpartisan candidate for the District IV councilmember seat, had lost the election by forty-one votes. The Supreme Court entered judgment in favor of Defendants, the Chief Election Officer and the State Office of Elections, holding that Plaintiff failed to show in his pleadings actual information of errors, mistakes, or irregularities sufficient to change the outcome of the election. View "Waters v. Nago " on Justia Law

After a trial, Defendant was convicted of committing the offense of prostitution. Defendant appealed, contending that there was insufficient evidence to prove the commission of a prostitution offense. The Intermediate Court of Appeals (ICA) affirmed. The Supreme Court affirmed the judgment on appeal of the ICA and clarified the prior-to-trial advisement required by State v. Lewis, holding (1) the ICA did not err in concluding that the evidence adduced at trial was sufficient to sustain Defendant’s conviction; (2) in order to more fully protect the right not to testify under the Hawaii Constitution, trial courts when informing the defendant of the right not to testify during the pretrial advisement must also advise the defendant that the exercise of this right may not be used by the fact finder to decide the case; and (3) although the court’s prior-to-trial advisement in this case did not inform Defendant that his silence could not be used against him if he did not testify, there was no error premised on the lack of judicial notice. View "State v. Monteil" on Justia Law

The Kahala Hotel and Resort collected a nineteen percent service charge on the purchase of food and beverages at Jason Kawakami’s reception. The hotel retained fifteen percent of the service charge as a “management share,” then reclassified and used that portion to pay for the banquet employees’ “wages.” Kawakami, individually and on behalf of all other similarly situated individuals, sued, alleging that Kahala Hotel violated Haw. Rev. Stat. 481B-14. The circuit court agreed, holding that, pursuant to section 481B-14, customers are entitled to know that a portion of the service charge would not be paid to employes as tip income but would instead become the property of the hotel to be used as the hotel deemed appropriate. The Intermediate Court of Appeals reversed, holding that no disclosure was required because the hotel had reclassified its fifteen percent management share to pay its employees’ wages. The Supreme Court reversed, holding section 481B-14 requires a hotel or restaurant that applies a service charge for food or beverage services to either distribute the service charge directly as tip income to the non-management employees who provided the services or disclose to its customers its practice of retaining the service charge. View "Kawakami v. Kahala Hotel Investors, LLC" on Justia Law

Defendant was charged with assault against a law enforcement officer in the second degree, resisting arrest, and disorderly conduct. Before trial, the circuit court denied defense counsel’s motion for withdrawal and substitution of counsel. A jury found Defendant guilty of the three charges. The Intermediate Court of Appeals affirmed, holding that the circuit court did not abuse its discretion in (1) denying Defendant’s motion for withdrawal and substitution of counsel, and (2) failing to sua sponte hold a hearing to determine Defendant’s competence to stand trial. The Supreme Court vacated the judgments of the lower courts, holding that, under the circumstances of this case, the circuit court (1) committed prejudicial error in denying Defendant’s motion for withdrawal and substitution of counsel; and (2) abused its discretion in not ordering a fitness examination. View "State v. Harter" on Justia Law

Plaintiff filed an election complaint to contest the November 2014 general election. Plaintiff was not listed on the ballot as a candidate for any officer in the November 2014 general election. Defendants moved to dismiss the complaint for lack of standing and, in the alternative, failure to state a claim upon which relief can be granted. The Supreme Court dismissed the complaint, holding that Plaintiff could prove no set of facts that would entitle her to any type of relief from the results of the general election, and therefore, Plaintiff failed to state a claim upon which relief could be granted. View "Dejean v. Nago" on Justia Law