Justia Hawaii Supreme Court Opinion Summaries

The State charged three defendants (collectively, Petitioners) of entering or remaining within the Kaho’olawe Island Reserve without being specifically authorized to do so, thereby committing the offense of entrance into the reserve. Petitioners filed a motion to dismiss, which the trial court denied. Petitioners were found guilty of the charges. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment of the ICA and the district court, holding that although the sufficiency of the complaints was not raised by either party, the complaints must be dismissed without prejudice because the charges failed to charge that Petitioners acted with the requisite state of mind by violating the law intentionally, knowingly, or recklessly. View "State v. Armitage" on Justia Law

The owner of certain property and surveying company filed a shoreline certification application with the Department of Land and Natural Resources for the property. Petitioners filed a notice of appeal of the proposed shoreline certification. In an amended decision, the Board of Land and Natural Resources (BLNR) concluded that Petitioners failed to establish that the proposed certified shoreline was not proper. The Supreme Court vacated the BLNR’s amended decision, holding (1) in making a shoreline determination pursuant to Haw. Rev. Stat. 205A-42, the BLNR must consider the historical evidence of the upper reaches of the wash of the waves; and (2) in this case, the BLNR’s amended decision establishing a certified shoreline for the subject property effectively failed to consider the historical evidence of the upper reaches of the wash of the waves and contained errors of law and erroneous findings of fact. Remanded. View "Diamond v. Dobbin" on Justia Law

After a bench trial, Petitioner was convicted of abuse of a family or household member. On appeal, Petitioner argued that the family court did not ensure that he had “fully” waived his right to a jury trial. The intermediate court of appeals (ICA) affirmed, concluding that under the totality of the circumstances, Petitioner had validly waived his right to a jury trial. The Supreme Court vacated the ICA’s judgment and the family court’s judgment, holding that the family court failed to ensure that Petitioner’s waiver of his right to a jury trial was voluntary. Remanded for a new trial. View "State v. Baker" on Justia Law

Petitioner was convicted of excessive speeding and no motor vehicle insurance. Petitioner appealed, arguing that the State did not lay sufficient foundation for the admission of the laser gun reading. The intermediate court of appeals (ICA) affirmed. Petitioner appealed, arguing that the ICA gravely erred in holding that the State laid sufficient foundation for the admission of the laser gun reading and challenging, for the first time, the sufficiency of the charge in the amended complaint because the amended complaint did not allege the requisite state of mind. The Supreme Court vacated the judgments of the lower courts, holding that inasmuch as the amended complaint against Petitioner failed to allege the requisite state of mind, the amended complaint must be dismissed without prejudice. View "State v. Pai " on Justia Law

In this dispute over a real estate transaction contract, final partial judgment and final judgment were entered against Szymanski. On September 19, 2011, Szymanski moved for reconsideration of the final partial and final judgments under Haw. R. Civ. P. 60(b). The circuit court denied the motion. On January 13, 2012, Szymanski filed a motion for reconsideration of the order denying his Rule 60(b) motion. The circuit court denied the motion on July 11, 2012. On August 10, 2012, Szymanski appealed from the order denying his Rule 60(b) motion and the order denying his motion for reconsideration. The intermediate court of appeals (ICA) dismissed the appeal as untimely because Szymanski did not file his notice of appeal within thirty days after the April 12, 2012 deemed denial of his January 13, 2012 motion for reconsideration. The Supreme Court vacated the ICA’s order dismissing the appeal for lack of jurisdiction because when a timely post-judgment tolling motion is deemed denied, it does not trigger the thirty-day deadline for filing a notice of appeal until entry of the judgment or appealable order. View "Title Guar. Escrow Servs., Inc. v. Waialea Resort Co., Ltd." on Justia Law

Petitioner filed a workers’ compensation claim with the Director of Labor and Industrial Relations seeking compensation for the aggravation of his asthma resulting from his exposure to vog while working as a school teacher. The Director denied Petitioner’s claim, and the Labor and Industrial Relations Appeals Board (LIRAB) affirmed. The intermediate court of appeals (ICA) affirmed the LIRAB’s decision. The Supreme Court vacated the ICA’s judgment and the LIRAB’s decision, holding that Petitioner was entitled to compensation pursuant to Haw. Rev. Stat. 386-3(a), which provides that if an employee suffers an injury proximately caused by employment, the employee shall be paid compensation. Remanded to the Director for a determination of the amount of compensation to be awarded. View "Van Ness v. State, Dep’t of Educ." on Justia Law

Petitioners executed a promissory note secured on a mortgage on their residence from a California corporation. The mortgage stated that Respondent, Mortgage Electronic Registration Systems, listed as mortgagee and nominee, held legal title to the interests granted by Petitioners in the mortgage. After Petitioners failed to make payments pursuant to the terms of the note, Respondent, acting as nominee, filed a complaint against Petitioners seeking foreclosure of the mortgage and sale of the property. The circuit court granted Respondent's motion for summary judgment and entered a foreclosure judgment. Petitioners' property was then sold to Respondent. The circuit court confirmed the sale despite Petitioners' assertion that Respondent lacked standing to bring the foreclosure action. The intermediate court of appeals affirmed. The Supreme Court affirmed, holding that Petitioners were precluded from raising the issue of Respondent's standing where (1) a standing objection is not unique to a confirmation of sale proceeding from which Petitioners appealed; and (2) Petitioners' failure to appeal the foreclosure judgment barred challenges to Respondent's standing under the doctrine of res judicata.View "Mortgage Elec. Registration Sys., Inc. v. Wise" on Justia Law

At issue in this case was a forty-nine acre parcel of land. After the County of Hawai’i and the County Planning Director (collectively, County Defendants) gave the subject property’s owners approval to subdivide the property, Plaintiff, an adjacent land owner, filed an action challenging the subdivision approval. The circuit court ultimately granted summary judgment on all counts for the County Defendants, concluding that no genuine issue of material fact existed in this case. The intermediate court of appeals (ICA) vacated the circuit court’s judgment and remanded for an order dismissing the case, concluding that Appellant failed to exhaust his administrative remedies, and therefore, the circuit court lacked jurisdiction to act on the complaint. The Supreme Court vacated the ICA’s judgment and remanded to the ICA for consideration of the remaining issues raised by Plaintiff in his appeal, holding that Appellant did not fail to exhaust administrative remedies. View "Kellberg v. Yuen" on Justia Law

Defendant was tried for attempted murder in the second degree. During the proceedings, Defendant expressed his desire to proceed pro se. The circuit court determined that Defendant waived his right to counsel, and Defendant was pro se for the rest of the trial. After the jury returned a guilty verdict, Defendant’s standby counsel filed a motion to withdraw as standby counsel and that substitute counsel be appointed to assist Defendant post-trial and on appeal. The circuit court allowed standby counsel to withdraw but did not appoint substitute counsel for Defendant’s post-verdict motions or for sentencing. The Supreme Court remanded the case, holding that the circuit court erred (1) by not appointing substitute counsel for Defendant’s post-verdict motions because post-verdict proceedings are critical stages in the prosecution; and (2) by not appointing Defendant substitute counsel for sentencing. View "State v. Pitts" on Justia Law

In dispute in this case was whether Plaintiffs were entitled to attorneys' fees and costs in litigating the underlying case. In the underlying case, Plaintiffs sued the Department of Hawaiian Home Lands (DHHL) and the State, arguing that the State violated its constitutional duty to sufficiently fund DHHS in order to rehabilitate native Hawaiian beneficiaries and that the DHHL breached its obligations to the beneficiaries of trust lands for several reasons. The first issue in the instant case was the extent to which Plaintiffs "prevailed" in the underlying case. The Supreme Court denied Plaintiffs' request for attorneys' fees and costs, holding (1) Plaintiffs prevailed on appeal; (2) Plaintiffs arguably established an entitlement to attorneys' fees under the private attorney general doctrine; but (3) Plaintiffs' request for appellate attorneys' fees was barred by the State's sovereign immunity.View "Nelson v. Hawaiian Homes Comm'n" on Justia Law