Justia Hawaii Supreme Court Opinion Summaries

This appeal arose from a property title dispute between Defendant, who purchased the property in 2007, and Plaintiff, which later acquired a quitclaim deed to the property following a judicial foreclosure. After Defendant refused to vacate the property, Plaintiff filed the underlying action, requesting a judgment for immediate and exclusive possession of the property and a writ of possession. The circuit court entered an order granting Plaintiff’s motion for summary judgment and issued a writ of possession. Defendant filed post-judgment motions and then filed a notice of appeal from the summary judgment. The circuit court denied Defendant’s post-judgment motions. The intermediate court of appeals (ICA) vacated the summary judgment and remanded based on Defendant’s post-judgment declaration. The Supreme Court vacated the ICA’s judgment and remanded, holding that the ICA erred in relying upon Defendant’s post-judgment motion as a basis to find disputed facts with regard to the motion for summary judgment. View "Kondaur Capital Corp. v. Matsuyoshi" on Justia Law

Defendant was charged with and convicted of the offense of solicitation with animals in Waikiki Special District based on “an exchange of cash immediately following the activity of picture taking” with Defendant’s birds. Defendant appealed, arguing that the State failed to provide sufficient evidence regarding the element of solicitation. The intermediate court of appeals (ICA) affirmed. The Supreme Court reversed, holding (1) an element of the offense of solicitation with animals in Waikiki Special District is the use of a live animal to request or demand money or gifts; and (2) there was insufficient evidence to prove this element of the offense. View "State v. Abel" on Justia Law

Plaintiff Nelson Waikiki, Jr. was one of seven candidates for the Maui County Mayoral seat in the August 9, 2014 special primary election. Plaintiff received the fourth highest number of votes in the election. On August 22, 2014, Waikiki requested a re-vote or a re-count due to conspiracy and corruption by election officials. Chief Election Officer Scott Nago moved to dismiss the complaint as untimely and for failure to state a claim. The Supreme Court granted the motion, holding that Waikiki failed to present specific facts or actual information of mistakes or error sufficient to change the results of the election, and therefore, Waikiki could prove no set of facts that would entitle him to relief. View "Waikiki v. Nago " on Justia Law

At issue in the case was a proclamation made by Chief Election Officer Scott Nago on Friday August 8, 2014 that closed two polling places on the Big Island and postponed the elections for Precincts 04-01 and 04-02. The next day, the primary election went forward as scheduled. On Friday, August 15, 2014, the election proceeded for Precincts 04-01 and 04-02 and was subsequently completed. On August 21, 2014, Plaintiffs, none of whom identified were registered voters of precincts that were closed on Saturday, August 9, 2014 or candidates for elected office, filed an election contest complaint against Nago and the Office of Elections, alleging that Nago should be fired because voters were denied their right to vote. The Supreme Court dismissed the complaint, holding (1) Plaintiffs were not proper parties to the election contest and lacked the requisite standing under Haw. Rev. Stat. 11-172; and (2) even if Plaintiffs had standing, the complaint failed to set forth any allegations that would demonstrate errors, mistakes, or irregularities that would change the election result. View "Cermelj v. Nago " on Justia Law

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