Justia Hawaii Supreme Court Opinion Summaries

During their marriage, Ray and Sandra signed three documents establishing the division and distribution of their martial partnership property upon divorce. The documents included a handwritten document, a memorandum of understanding (MOU) and a quitclaim deed. Sandra subsequently filed a complaint for divorce. Nothwithstanding the documents, the family court awarded Ray and Sandra each one-half interest in the property, concluding that the quitclaim deed was unenforceable because they were unconscionable and that all three documents were unenforceable because Ray acted under duress and coercion when he signed them. The Intermediate Court of Appeals (ICA) vacated in part the family court’s divorce decree, concluding that the quitclaim deed was not unconscionable and that Ray executed both the quitclaim deed and the MOU voluntarily. The Supreme Court vacated the judgment of the ICA and vacated the family court’s divorce decree, holding (1) the quitclaim deed did not affect the disposition of the parties’ marital partnership property upon divorce, and therefore, the ICA erred in concluding that the quitclaim deed was an enforceable separation agreement; and (2) the MOU was enforceable because it was not unconscionable and was entered into voluntarily. Remanded. View "Balogh v. Balogh" on Justia Law

Oahu Publications (“OP”) successfully obtained a judgment against the Governor and was awarded attorneys’ fees. The Governor appealed the attorneys' fees award. The Intermediate Appellate Court (ICA) dismissed the appeal because of an error in the circuit court’s award. The circuit court corrected its judgment, and the Governor again appealed. The ICA affirmed the award of attorneys’ fees. OP then filed a request for appellate fees in the ICA, which included fees accrued during both the first and second appeals. The ICA denied the request for fees incurred during the first appeal on the grounds that it was untimely but granted the request with respect to the second appeal. The Supreme Court vacated in part the ICA’s judgment, holding that the ICA erred in not considering OP’s request for fees and costs incurred during the first appeal, as (1) OP was not a prevailing party for purposes of Haw. Rev. Stat. 92F-15(d) until after the second appeal was decided; and (2) even if OP could have filed a request for fees and costs pursuant to section 92F-15(d) upon dismissal of the first appeal, the ICA had the discretion to consider an untimely request for fees and costs. Remanded. View "Oahu Publ’ns, Inc. v. Abercrombie" on Justia Law

During the trial of State v. Deedy and on the fifth day of jury deliberations, the circuit court conducted five separate court proceedings that were not open to the public. The transcripts from the court sessions were subsequently sealed, and a mistrial was declared as a result of a deadlocked jury. Petitioners, the Honolulu Star-Advertiser and Hawaii News Now, filed petitions for writs of prohibition and mandamus seeking to prohibit the circuit court from sealing any portion of the trial transcript and to prohibit the court from closing the courtroom in a similar manner in a re-trial of State v. Deedy and in any other criminal proceeding. On remand, the circuit court unsealed the transcript. The Supreme Court (1) dismissed the writ of prohibition as moot because the circuit court already unsealed the transcript of the closed proceedings; (2) denied the writ of mandamus as unnecessary in light of the directive of this opinion; and (3) adopted procedures that a court is required to follow before denying public access to a transcript of a closed proceeding. View "Oahu Publ’ns, Inc. v. Hon. Karen Ahn" on Justia Law

Appellant was permanently incapacitated while lifting boxes during a work shift for the City and County of Honolulu. Appellant applied for service-connected disability retirement benefits with the Board of Trustees of the Employees’ Retirement System (ERS) under Haw. Rev. Stat. 88-79, which allows for such benefits if an ERS member was permanently incapacitated for duty as the “natural and proximate result” of an “accident” occurring while in the actual performance of a duty “at some definite time and place.” The Board denied Appellant’s application, concluding (1) Appellant’s injury was not an “accident” because Appellant had failed to show that the injury occurred at “some definite time and place”; and (2) Appellant’s permanent incapacity was not the “natural and proximate result” of the incident. The circuit court affirmed. The Supreme Court vacated the decision of the circuit court, holding that the “definite time and place” language in section 88-79 does not preclude the recovery of benefits despite Appellant’s inability to pinpoint the precise moment of injury where there was no dispute that Appellant was injured during her work shift. Remanded for a determination of whether Appellant’s permanent incapacity was not “the natural and proximate result” of the alleged incident. View "Panado v. Bd. of Trustees Employees' Ret. Sys." on Justia Law

These appeals stemmed from an action Plaintiff filed against Hawaii Employers Medical Insurance Company (HEMIC) and others. Plaintiff eventually filed separate appeals regarding two orders of the circuit court granting motions in favor of HEMIC. The intermediate court of appeals (ICA) vacated one order but denied Plaintiff’s request for appellate costs related to the appeal of that order. The Supreme Court vacated the judgment of the ICA pertaining to its denial of appellate costs and awarded costs in favor of Plaintiff in the amount of $628, holding (1) the ICA applied an erroneous legal standard in denying costs; and (2) because Plaintiff was the prevailing party on the disputed issue on appeal, he was eligible for an award of costs related to the appeal. View "Jou v. Argonaut Ins. Co." on Justia Law

Appellant, an inmate in custody, filed a petition post-conviction relief under Haw. R. Penal P. 40, alleging that he was incompetent to stand trial, his trial counsel and appellate counsel provided ineffective assistance, and prosecutorial misconduct. The circuit court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that Appellant’s appeal was without merit where Appellant failed to establish a colorable claim that (1) he was incompetent to stand trial; (2) his appellate counsel provided ineffective assistance for failing to appeal the issue of Appellant’s alleged incompetence to stand trial; (3) his trial counsel was ineffective; and (4) the prosecutor committed misconduct that would warrant relief under Rule 40. View "Fanelli v. State " on Justia Law

United Public Workers, AFSCME, Local 646, AFL-CIO (“UPW”) filed an action on behalf of the employees it represented, alleging (1) then-Governor Lingle and members of her administration retaliated against UPW members for filing a lawsuit opposing her statewide furlough plan; and (2) the State was unlawfully privatizing positions customarily performed by civil servants under the merit system. The circuit court dismissed the complaint based on a lack of jurisdiction. The intermediate court of appeals (ICA) vacated the circuit court’s judgment and remanded with instructions to stay the action pursuant to the primary jurisdiction doctrine so the parties could pursue appropriate administrative remedies before the Hawaii Labor Relations Board (HLRB). The Supreme Court primarily affirmed, holding (1) the ICA did not err in concluding that the primary jurisdiction doctrine was applicable to UPW’s retaliation claims because the claims required the resolution of issues that have been placed within the special competence of the HLRB, and that a stay, rather than a dismissal, was appropriate under the circumstances; and (2) the primary jurisdiction doctrine did not apply to UPW’s privatization claims, and therefore, the circuit court erred in dismissing these claims, and the ICA erred in referring the claims to the HLRB. Remanded. View "United Pub. Workers, AFSCME, Local 636, AFL-CIO v. Abercrombie" on Justia Law

Kauai Springs, Inc., a water bottling and distribution company, filed an application for three zoning permits related to the continued operation of its water bottling facility on land located in Koloa, Kauai. The Planning Commission of the County of Kauai denied the permits, notified Kauai Springs that continued operation on the property constituted a land use violation, and ordered Kauai Springs to shut down its operations on the property. The circuit court reversed in part and vacated in part the Commissioner’s decision and order and ordered that all three permits be issued. The intermediate court of appeals (ICA) vacated the circuit court’s final judgment and remanded to the Commission for consideration of whether Kauai Springs could meet the requirements for the permits. The Supreme Court affirmed to the extent the ICA vacated the circuit court’s final judgment, holding that the Commission’s findings of fact were not erroneous, its conclusions of law were correct, and its decision to deny the permits was not arbitrary and capricious, but clarity and completeness in its decision were lacking. Remanded to the Commission to clarify its findings of fact and conclusions of law. View "Kauai Springs, Inc. v. Planning Comm’n" on Justia Law

The State filed a misdemeanor complaint against Defendant charging him with one count of abuse of a family or household member (domestic abuse). The complaint stated that Defendant engaged in the abuse for more than two years “as a continuing course of conduct.” The circuit court dismissed the State’s complaint without prejudice, concluding that domestic abuse cannot be charged on a continuous conduct theory. The intermediate court of appeals (ICA) reversed, determining that, in some cases, domestic abuse may be charged as a continuous offense. The Supreme Court reversed the ICA’s judgment and affirmed the circuit court’s order dismissing the State’s complaint, holding that an alleged two-year period of domestic abuse cannot be charged on a continuing course of conduct theory. View "State v. Decoite" on Justia Law

In 2000, Colleen Collins and John Wassell were joined as a married couple in a ceremony. After the marriage ceremony, the couple did not submit the completed license and certificate of marriage to the State Department of Health due to concerns about the marriage’s financial implications. Afterwards, Collins and Wassell went on a honeymoon, began living together, and shared a joint bank account. In 2005, the couple legally married. In 2007, Collins filed for divorce against Wassell. Collins argued that she was entitled to an equalization payment for her contributions during the period of premarital cohabitation. The family court determined that Collins and Wassell did not form a premarital economic partnership within the meaning of Helbush v. Helbush. The Supreme Court vacated the divorce decree and the property division and equalization provisions in the decree, holding that the family court (1) applied incorrect legal principles when considering the nature and degree to which the parties applied their financial resources, energies, and efforts for each other’s benefit; and (2) clearly erred in concluding that the parties did not form a premarital economic partnership. View "Collins v. Wassell" on Justia Law