Justia Hawaii Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the circuit court's judgment of conviction and sentence, holding that, contrary to Defendant's arguments on appeal, the requirements of Haw. Rev. Stat. 327C-1 does not apply to all criminal cases involving death.Defendant was charged with murder in the second degree. A jury found Defendant guilty of the lesser-included offense of manslaughter based on reckless conduct. The ICA affirmed. The Supreme Court affirmed, holding (1) a death determination under section 327C-1 was not required or implicated under the circumstances of this case because there was sufficient evidence for a reasonable juror to conclude that death was proven beyond a reasonable doubt; and (2) the circuit court did not err in failing to instruct the jury on the lesser-included offense of reckless endangering second. View "State v. Angei" on Justia Law

The Supreme Court vacated the decision of the intermediate court of appeals (ICA) affirming order of the circuit court denying Defendant's motion to dismiss indictment against him, the court's judgment of conviction and sentence, and the later order of restitution, holding that the circuit court abused its discretion by denying Defendant's motion to dismiss the indictment.In his motion to dismiss the indictment against him, Defendant argued that the prosecutor committed prosecutorial misconduct by before the grand jury by improperly eliciting testimony that he had invoked his right to remain silent. The circuit court denied the motion to dismiss, and Defendant entered a no-contest plea to assault in the first degree. The ICA affirmed. The Supreme Court vacated the lower courts' decisions, holding (1) the prosecutor violated Defendant's due process right to a fair and impartial grand jury hearing by eliciting testimony that Defendant invoked his right to remain silent; and (2) the circuit court erred by ordering Defendant to pay $1,461,444 in restitution. View "State v. Borge" on Justia Law

The Supreme Court affirmed the order of the Land Use Commission (LUC) denying Petitioners' petition for a declaratory order challenging the construction of the Thirty Meter Telescope (TMT), holding that Haw. Rev. Stat. 205-2(e) does not authorize the Commission to exclude or enforce certain land uses within conservation districts.Petitioners in this case sought to use the LUC's districting authority in a manner that would compel the removal of all astronomy facilities located within the Astronomy Precinct. The LUC denied the petition, and Petitioners appealed. The Supreme Court affirmed, holding (1) this Court had jurisdiction to directly review Petitioners' appeal; (2) the LUC correctly determined that it lacked jurisdiction to issue the requested declaratory orders; and (3) Petitioners were not entitled to relief on their remaining claims of error. View "In re Petition of Ku'ulei Higashi Kanahele" on Justia Law

In this foreclosure dispute, the Supreme Court held that Haw. Rev. Stat. 514B-146(n) provides a scheme for distributing rents following a lender's foreclosure against an association and that the Association of Apartment Owners of Elima Lani Condominiums (AOAO) may be entitled to all or some of the rent collected for Nationstar Mortgage, LLC in this case.AOAO foreclosed an a unit owned by Thomas and Sarah David for failure to pay common assessments. Thereafter, Nationstar filed a complaint for foreclosure of the Davids' unit, alleging that the Davids had defaulted on their mortgage. The circuit court entered summary judgment and a decree of foreclosure in favor of Nationstar after AOAO came into possession of the unit. Nearly eleven months later after the foreclosure sale of the unit, the circuit court confirmed the foreclosure sale. Before the Supreme Court was whether AOAO was entitled to rents that accrued from the unit during the period between summary judgment and the confirmation of sale. The Supreme Court vacated the circuit court's judgment to the extent it awarded post-foreclosure rents to Nationstar and remanded for a calculation of the amount AOAO was owed from post-foreclosure units, holding that AOAO may be entitled to all or some of the rent collected for Nationstar after summary judgment. View "Nationstar Mortgage, LLC v. Ass'n of Apartment Owners of Elima Lani Condominiums" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing without prejudice the complaints in Appellees' cases, holding that the complaints did not have to comply with Haw. Rev. Stat. 805-1, and the State properly initiated the criminal proceedings against Appellees.The State charged Appellees by complaint with operating a vehicle under the influence of an intoxicant (OVUII). Appellees each filed a motion to dismiss for defective complaint and improper arraignment, arguing that the complaint was not supported by the complainant's signature or a declaration submitted in lieu of affidavit. The district court granted the motions to dismiss and dismissed the cases without prejudice. The State appealed, arguing that the district court erred in concluding that the subject charging instruments were required to comply with section 805-1. The Supreme Court agreed and reversed, holding (1) section 805-1 applies only to complaints for a penal summons or an arrest warrant; and (2) the district court erred in dismissing the complaints charging Appellees with OVUII. View "State v. Mortensen-Young" on Justia Law

The Supreme Court affirmed the decision of the Public Utilities Commission (PUC) rejecting the power purchase agreement between Hu Honua and the Hawai'i Electric light Company, Inc., holding that there was no error in the PUC's decision to reject the power purchase agreement between the parties.At issue was the denial of Hua Honua's request for regulatory approval to supply energy to Hawai'i Island using a biomass power plant. In declining to approve the project on remand, the PUC found that the project would produce massive greenhouse gas (GHG) emissions and significantly increase costs for rate-payers. The Supreme Court affirmed, holding that the PUC understood its public interest-minded mission and properly followed this Court's remand instructions to consider the reasonableness of the proposed project's costs in light of its GHG emissions and the impact on Intervenors' right to a clean and healthful environment. View "In re Haw. Electric Light Co., Inc." on Justia Law

The Supreme Court overruled Maha-ulepu v. Land Use Commission, 790 P.2d 906 (1990), superseded by statute, 2005 Haw. Less. Laws Act 205, 2-3 at 669-71, which held that a use not permitted under Haw. Rev. Stat. 205-4.5(a)(6) could be authorized by special use permit, holding that it was incorrectly decided.At issue was Ho'omoana Foundation's proposed overnight campground development for unhoused and commercial campers on Class B land in an agricultural district in Maui could be authorized by special use permit or whether a district boundary amendment was required. The Supreme Court held (1) the specific exclusion of overnight camps from permitted uses in Haw. Rev. Stat. 205-4.5(a)(6) sets forth that the public and private recreation use of overnight camps is not permitted in Class A and B land in agricultural districts and cannot be permitted by special use permits; (2) Maha'ulepu is overruled; and (3) because the proposed campground project included a public or private recreational overnight camp use, the project required a district boundary amendment. View "Ho'omoana Foundation v. Land Use Comm'n" on Justia Law

In this foreclosure proceeding, the Supreme Court vacated the judgment of the intermediate court of appeals (ICA) affirming the circuit court's order granting Deutsche Bank's motion for summary judgment on its complaint to foreclose a mortgage, holding that Deutsche Bank did not establish that it had standing to foreclose.In 2006, Blaine Yata executed a note and mortgage to New Century Mortgage Corporation. The mortgage was later assigned to Deutsche Bank National Trust Company, as trustee for Morgan Stanley ABS Capital I Inc. Trust 2006-NC4 (Deutsche Bank). When Yata defaulted on the note, Deutsche Bank brought a complaint to foreclose on the mortgage. The circuit court granted summary judgment for Deutsche Bank. The ICA affirmed. The Supreme Court vacated the ICA's judgment on appeal, holding (1) the ICA misapplied U.S. Bank Trust, N.A. v Verhagen, 489 P.3d at 419 (2021) in determining that Deutsche Bank's documents were admissible; and (2) even if the documents were admissible, they would not establish that Deutsche Bank had possession of the note when it filed the complaint. View "Deutsche Bank National Trust Co. v. Yata" on Justia Law

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) determining that Hawai'i law did not require the joinder of Defendant's traffic offenses with his assault offense, holding that the ICA did not err.Defendant was charged with two separate sets of offenses - traffic offenses and an assault offense - that he argued arose from a single criminal episode. Defendant filed a motion to dismiss, arguing that Haw. Rev. Stat. 701-109 required the State to try the traffic offenses and the assault offense together. The circuit court granted the motion to dismiss. The ICA vacated the circuit court's order, holding that the traffic offenses and the assault offense were not so closely related in time, place, or circumstances that section 701-109(2) compelled the joinder of the two proceedings. The Supreme Court affirmed, holding that Hawai'i law did not require joinder under the circumstances. View "State v. Sardinha" on Justia Law

The Supreme Court answered two questions of law certified by the United States Bankruptcy Court for the District of Hawai'i concerning a putative class action alleging wrongful foreclosure.Specifically, the Court answered (1) an action alleging a wrongful nonjudicial foreclosure of land court property that seeks only damages against the foreclosing lender is not barred by the entry of a transfer certificate of title to a buyer at a foreclosure sale; and (2) the pendency of a putative class action tolls the time during which a class member may commence an individual action, and the time for commencing an individual action is tolled until a clear denial of class certification. View "Yanagi v. Bank of America" on Justia Law