Justia Hawaii Supreme Court Opinion Summaries

Plaintiff, a Hawaii non-profit corporation, entered into a lease agreement with Defendant, the trustee of a trust. Plaintiff subsequently began renting cabins on the property to the public. After a dispute arose between the parties regarding the terms of the lease, Plaintiff filed a complaint in the circuit court seeking a declaratory judgment that its commercial uses of the property and rental of cabins to the public was permitted under the lease, among other things. The circuit court granted summary judgment in favor of Defendant on Plaintiff's claim regarding cabin rentals but granted summary judgment in favor of Plaintiff on Defendant's counterclaims for breach of contract and unjust enrichment. The intermediate court of appeals (ICA) vacated summary judgment as to the issue of cabin rentals. The Supreme Court (1) affirmed the ICA regarding cabin rentals, holding that the portion of the lease delineating permissible uses of the property was ambiguous; and (2) reversed the ICA's judgment regarding Defendant's counterclaims for breach of contract and unjust enrichment because the issue of whether Plaintiff was prohibited by the lease from renting cabins to the general public had yet to be resolved on remand. Remanded.View "Hawaiian Ass'n of Seventh-Day Adventists v. Wong" on Justia Law

The Waikoloa Beach Villas condominium project was developed by Respondent, Sunstone Waikoloa, LLC. Petitioner, the Association of Apartment Owners of the Waikoloa Beach Villas, contacted Respondent to resolve issues resolving purported construction defects. Petitioner then filed a motion to compel mediation and arbitration. Respondent argued that it could not request arbitration because it had failed to comply with the requirements of the Declaration of Condominium Property Regime for the Villas. The Declaration imposed numerous requirements that Petitioner must meet before initiating arbitration or litigation proceedings against Respondent. The lower court granted Petitioner's motion. The intermediate court of appeals (ICA) reversed. The Supreme Court vacated in part and affirmed in part the judgment of the ICA, holding that section R.4(c) of the Declaration violated Haw. Rev. Stat. 514B-105(a) because it imposed limitations on Petitioner in arbitration or litigation more restrictive than those imposed on other persons. Remanded.View "Ass'n of Apartment Owners of Waikoloa Beach Villas v. Sunstone Waikoloa, LLC" on Justia Law

This case involved the disposition of property during divorce proceedings between Husband and Wife. In the divorce decree, the court provided that the property would be sold and the proceeds divided as proposed by the parties. Both parties subsequently filed post-decree motions. The family court later modified the decree as to the apportioned liability for capital gains taxes between Husband and Wife. The Court of Appeals (ICA) affirmed the court's order modifying the decree. The Supreme Court vacated the ICA's judgment affirming the order on post-decree relief and vacated the family court's order on post-decree relief, holding that the family court was foreclosed from modifying the divorce decree because the circumstances here did not permit such modification under the Hawaii Family Court Rules. Remanded.View "Thomas-Yukimura v. Yukimura" on Justia Law

The State Health Planning & Development Agency (SHPDA) granted Rainbow Dialysis (Rainbow) a conditional certificate of need to establish two dialysis facilities in Maui. Liberty Dialysis-Hawaii (Liberty), another Maui dialysis provider, sought reconsideration of SHPDA's decision. A five-member reconsideration committee unanimously approved Rainbow's certificate of need. Liberty appealed, arguing that the SHPDA administrator and another committee member should have been disqualified from participating in the reconsideration decision. The circuit court affirmed, holding that the SHPDA administrator should have been disqualified but his participation was harmless. The Supreme Court affirmed, holding that neither the administrator nor the other committee member was disqualified from participating in the reconsideration decision. View "Liberty Dialysis-Hawaii, LLC v. Rainbow Dialysis, LLC" on Justia Law

Petitioners filed a complaint against Respondents for violations of the Uniform Fraudulent Transfers Act (UFTA). The circuit court dismissed the action without discussing Respondents’ argument that Petitioners’ claim was untimely. Petitioners appealed. Respondents cross-appealed, asserting that Petitioners’ UFTA claim was time-barred. The intermediate court of appeals (ICA) ruled on the statute of limitations issue raised in the cross-appeal and concluded that Petitioners’ UFTA claim should have been dismissed as untimely, holding that the one-year limitations period begins when a transfer, rather than its fraudulent nature, is discovered. The Supreme Court vacated the judgment of the ICA, holding (1) the one-year limitations period under UFTA begins on the date a transfer commences when a plaintiff discovers or could reasonably have discovered a transfer’s fraudulent nature; and (2) the ICA erred in its ruling on the statute of limitations issue and should have decided the merits of the claim raised in Petitioner’s appeal. Remanded. View "Schmidt v. HSC, Inc." on Justia Law

Defendant was convicted of murder in the second degree and several other charges. At issue before the Supreme Court was whether the circuit court plainly erred in excluding expert testimony on cocaine use where the defense expert was prepared to testify that, to a reasonable degree of scientific probability, the victim was under the influence of cocaine at the time of the shooting. The Supreme Court vacated Defendant’s convictions for second-degree murder and carrying or use of a firearm while engaged in the commission of a separate felony, holding that the circuit court committed reversible error by excluding the testimony on the grounds that the testimony must be offered to a reasonable degree of scientific certainty. Remanded. View "State v. Deleon" on Justia Law

Petitioner was convicted of excessive speeding. The intermediate court of appeals (ICA) affirmed. Petitioner sought review of the judgment of the ICA, challenging for the first time the sufficiency of the charge on the grounds that the amended complaint did not allege the required state of mind to prove the charge of excessive speeding. 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, which was an essential fact of the offense of excessive speeding, the amended complaint must be dismissed. View "State v. Pierce " on Justia Law

Petitioner was convicted of prostitution. The intermediate court of appeals (ICA) affirmed. The ICA sua sponte raised the issue of whether the charge was deficient for failing to allege the requisite mens rea, which was an essential fact of the offense of prostitution. The ICA, inter alia, held that Petitioner “waived any sufficiency to the charge for failure to allege a mens rea” by not objecting on this basis and by not asserting the claim on appeal. The Supreme Court vacated the judgments of the lower courts, holding that, inasmuch as the complaint against Petitioner failed to allege the requisite state of mind for the offense of prostitution, the complaint must be dismissed. View "State v. Shyanguya " on Justia Law

Petitioner was convicted of one count of operating a vehicle under the influence of an intoxicant (Count I) and one count of accidents involving damage to vehicle or property (Count II). The intermediate court of appeals (ICA) affirmed. Petitioner sought review of the judgment of the ICA, raising a challenge to the sufficient of the complaint with respect to Count II. Specifically, Petitioner claimed that Count II failed to charge a requisite state of mind. The Supreme Court vacated the judgment of the lower courts, holding that inasmuch as Count II of the complaint against Petitioner failed to allege the requisite state of mind, it must be dismissed. View "State v. Tongg " on Justia Law

Trustee alleged that Defendants owned an interest in a parcel of land and moved for summary judgment to partition their interest along with the remainder of the parcel. The circuit court granted summary judgment for partition, directed that the parcels be sold at a public auction, and ordered the sale proceeds to be distributed pursuant to court order. Defendants’ property was sold to Trustee at the public auction. The sale was confirmed to Trustee pursuant to a confirmation order. Defendants appealed from the confirmation order. The intermediate court of appeals (ICA) dismissed Defendants’ appeal for lack of jurisdiction because no final judgment had been entered in the case. The Supreme Court vacated the ICA’s dismissal order and remanded to the ICA for disposition of the appeal, holding that the confirmation order met the requirements of appealability under the doctrine announced in Forgay v. Conrad, which addresses the narrow relaxation of the finality rule for orders transferring property. View "Lambert v. Teisina" on Justia Law