Justia Hawaii Supreme Court Opinion Summaries

The State charged Defendant with harassment. Before trial commenced, the district court granted Defendant’s motion to dismiss the complaint on the ground that disjunctive wording in the complaint made it difficult to prepare a defense. The intermediate court of appeals affirmed, concluding that because the complaint charged two forms of non-synonymous conduct disjunctively, the charge did not provide Defendant with adequate notice. The Supreme Court reversed, holding (1) when charging a defendant under a single subsection of a statute, the charge may be worded disjunctively in the language of the statute as long as the acts charged are reasonably related so that the charge provides sufficient notice to the defendant; and (2) the complaint in this case met due process requirements regardless of whether the disjunctively charged acts were synonymous or non-synonymous. View "State v. Codiamat" on Justia Law

The State indicted Petitioner on kidnapping and assault in the second degree. A jury found Petitioner guilty of kidnapping and of the lesser included offense of assault in the third degree. Petitioner filed a motion for judgment of acquittal, arguing (1) the State failed to prove venue was proper in this case; and (2) the Class A felony kidnapping should be reduced to Class B kidnapping because the complainant did not sustain serious or substantial injury as shown by the jury acquitting Petitioner of assault in the second degree. The trial court denied the motion. The Supreme Court affirmed the convictions, holding (1) because several witnesses testified that the offense occurred on the island of Oahu, there was sufficient evidence to demonstrate the first judicial circuit was the correct venue; and (2) while the State must prove beyond a reasonable doubt that substantial bodily injury was caused by Defendant in order to disprove the mitigating defense that reduces the offense of kidnapping from a Class A felony to a Class B felony, the State disproved one of the three elements of the Class B mitigating defense beyond a reasonable doubt to establish that Defendant was not entitled to the defense. View "State v. Bailey " on Justia Law

In April 2010, the State Senate expressly rejected Duane Kanuha's nomination for a second term as a commissioner on the State Land Use Commission (LUC). Following the Senate's rejection, Kanuha continued to serve on the board and to participate in the LUC's consideration of a development project involving the reclassification of agricultural land for urban use. Sierra Club filed an action to disqualify Kanuha from serving on the LUC and to invalidate the actions Kanuha had taken with regard to the development project. The LUC denied the action. That same day, LUC voted to approve the development project. Without Kanuha's vote, the LUC lacked the requisite number of votes to approve the reclassification. The circuit court reversed the LUC's decision and order. The ICA reversed, determining that Kanuha continued to serve as a valid holdover member of the LUC after the Senate's rejection of his nomination for a second term. The Supreme Court reversed, holding (1) Kanuha was not a valid holdover when he voted on the reclassification; (2) Kanuha did not qualify as a de facto member of the LUC; and (3) therefore, Kanuha's actions taken with respect to the reclassification petition were invalid. View "Sierra Club v. Castle & Cooke Homes Haw., Inc. " on Justia Law

After a jury trial, Petitioner was convicted of robbery in the first degree and assault in the first degree. The Supreme Court reversed Petitioner's conviction of first degree assault but affirmed his conviction of second degree robbery, holding (1) Petitioner could not be convicted of both robbery in the first degree and assault in the first degree inasmuch as the element of infliction of severe bodily injury was common to both offenses, the jury relied on the same conduct of Petitioner to satisfy this element for both offenses, and the findings incorporated in the verdicts were inconsistent; and (2) a specific unanimity instruction was not required in this case. View "State v. Santiago" on Justia Law

The County of Kauai Planning Commission approved a subdivision application for a Trust's development of land in Koloa, Kauai. During the Commission's consideration of the application, the parties assumed that a historic road (Road) that the Trust needed to breach to provide access into the subdivision belonged to the County of Kauai. Plaintiff filed a civil complaint alleging several claims against Defendants, including breaches of the public trust. Plaintiff subsequently amended his complaint because he discovered that the road belonged to the State and not the County and asserted two additional claims against the Trust for allegedly breaching the Road. The circuit court dismissed the claims, concluding (1) because the State had not given its approval to breach the Road, the issues raised in Plaintiff's complaint were not ripe; and (2) even if Plaintiff had claims that were ripe and severable, the court had the discretion to dismiss the claims in the interest of judicial economy. The Supreme Court vacated the circuit court's final judgment, holding (1) all of Plaintiff's claims were ripe for adjudication; and (2) the circuit court erred in dismissing claims on the basis of judicial economy. Remanded. View "Blake v. County of Kauai Planning Comm'n" on Justia Law

Pacific Lightnet, Inc. (PLNI) brought claims against Time Warner, asserting that it had been wrongfully billed by Time Warner for services that it had never received and that it was owed credits to its account from Time Warner based on assets PNLI had purchased, called Feature Group D claims. The circuit court entered judgment for Time Warner on all claims, notwithstanding a jury verdict in favor of PLNI on certain claims. The intermediate court of appeals (ICA) affirmed the circuit court's dismissal of the Feature Group D claims based on the doctrine of primary jurisdiction and vacated the jury verdict on those same claims. PLNI appealed, arguing, inter alia, that the ICA erred in vacating the jury's verdict because it violated the filed-rate doctrine. The Supreme Court affirmed in part, vacated in part, and remanded, holding (1) the circuit court erred in invoking the primary jurisdiction doctrine to dismiss this case; and (2) inasmuch as the filed-rate doctrine applied, the circuit court erred in failing to instruct the jury that Appellant could not recover for any claims involving charges not filed within 120 days of receipt of billing in accordance with the Hawaii Public Utilities Commission and Federal Communications Commission filed tariffs. View "Pacific Lightnet, Inc. v. Time Warner Telecom, Inc." on Justia Law

Defendant was charged with committing the offense of abuse of family or household members (AFHM). Defense counsel moved to dismiss the complaint, arguing (1) the family circuit court lacked jurisdiction because Defendant was arraigned in the family circuit court rather than district court in violation of Hawaii Rules of Penal Procedure 10(a); and (2) the complaint was insufficient for failure to define "physical abuse" or "family or household member." The family circuit court denied the motion. The intermediate court of appeals (ICA) upheld the judgment of the family circuit court, holding (1) any impropriety on the part of the family circuit court with respect to the arraignment was harmless error; and (2) the charge was sufficient. The Supreme Court vacated the ICA's judgment and the family court's judgment of conviction and sentence and remanded to the family circuit court to dismiss the case without prejudice, holding (1) because the family circuit court failed to arraign Petitioner in accordance with Rule 10(a), the case must be dismissed without prejudice; and (2) the charge was sufficient inasmuch as it "fully defined the offense in unmistakable terms readily comprehensible to persons of common understanding." View "State v. Basnet" on Justia Law

A homeowners association commenced a judicial foreclosure on Defendant's condominium unit after Defendant failed to pay her association fees and dues. The circuit court subsequently entered a default judgment and foreclosure decree. On May 29, the circuit court confirmed the sale to a third-party purchaser. Defendant filed a motion for reconsideration on the order and judgment confirming the sale. The circuit court did not rule on the motion within ninety days, and the motion was automatically deemed denied on September 5. On October 16, Defendant appealed the May 29 judgment. The intermediate court of appeals (ICA) dismissed Defendant's appeal for untimeliness, concluding that Defendant failed to timely appeal following the deemed denial of a post-judgment tolling motion. Specifically, the ICA determined that Defendant should have filed her notice of appeal by October 5, thirty days after the deemed denial of her motion. The Supreme Court vacated the ICA's dismissal order, holding that 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. Remanded. View "Ass'n of Condo. Homeowners of Tropics at Waikele v. Sakuma" on Justia Law

Petitioner was a passenger in an uninsured vehicle that was in an accident. At the time, Petitioner had a certificate policy issued by the Department of Human Services through its Joint Underwriting Program (JUP). The JUP Bureau determined Petitioner was entitled to receive benefits under the JUP and assigned Petitioner's claim to Respondent. Respondent, however, denied Petitioner's request for coverage because Petitioner's certificate policy did not include uninsured motorist coverage. Petitioner sued Respondent, alleging claims of, inter alia, bad faith. The circuit court entered summary judgment for Respondent. The intermediate court of appeals (ICA) affirmed, concluding that an underlying insurance contract was required to assert a claim of bad faith against an insurer. The Supreme Court vacated the judgments of the lower courts, holding (1) under the JUP, the insurer assigned to a claim owes the same rights to the person whose claim is assigned to it as the insurer would owe to an insured to whom the insurer had issued a mandatory motor vehicle insurance policy; (2) the insurer's good faith covenant implied in such motor vehicle policies applies to claimants under the assigned claim procedure despite the absence of an insurance policy; and (3) accordingly, Respondent owed Petitioner a duty of good faith.View "Willis v. Swain " on Justia Law

Respondents, the City and County of Honolulu and certain individuals, banned Petitioners, two stagehands, from working at certain City-owned facilities based on Petitioners' involvement in a charitable concert featuring the City's mayor. After a jury-waived trial, the circuit court entered judgment in favor of Respondents on all claims, including Petitioners' claims that the ban was unconstitutional. The intermediate court of appeals affirmed. The Supreme Court vacated the lower courts' judgments, holding that the City's ban interfered with Petitioners' liberty interests under the Hawaii Constitution and that the City failed to satisfy due process by instituting the ban without giving Petitioners notice and an opportunity to be heard. Remanded. View "Minton v. Quintal" on Justia Law