Justia Hawaii Supreme Court Opinion Summaries

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

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