Justia Hawaii Supreme Court Opinion Summaries

Defendant entered a conditional no contest plea to operating a vehicle under the influence of an intoxicant (OVUII). The district court convicted Defendant over OVUII under Haw. Rev. Stat. 291E-61(a)(1) and (a)(3). Defendant conditioned his plea on his ability to appeal his contention that the charge was defective because it did not allege a state of mind. Defendant's written submission of plea form, however, contained a conditional plea only to the section 291E-61(a)(1) method of proof. The intermediate court of appeals (ICA) vacated Defendant's convictions as to both section 291E-61(a)(1) and (a)(3) but determined that, on remand, the State could proceed to prosecute Defendant under the section 291E-61(a)(3) method of proof. The Supreme Court affirmed the ICA's judgment vacating the district court's judgment but directed that, on remand, the state was precluded from prosecuting Defendant under the section 291E-61(a)(3) method of proof, as, in the circumstances presented in this case, permitting the State to proceed with prosecution under section 291E-61(a)(3) would constitute a breach of the plea agreement in violation of Defendant's due process rights. Remanded. View "State v. Nakano" on Justia Law

Respondents in this case included Kaiser Foundation Health and Kaiser Foundation Hospitals (collectively, Kaiser). Michael Siopes, a public school teacher, enrolled in a Kaiser health plan offered through the Hawaii Employer-Union Health Benefits Trust Fund (EUTF). Michael was later diagnosed with cancer by a Kaiser medical professional. Michael and his wife, Lacey, subsequently consulted a medical team at Duke University Medical Center. The Duke team determined that Kaiser's diagnosis was erroneous and recommended a different treatment plan. Michael received treatment at Duke that was ultimately successful. Kaiser denied Michael's request for coverage. Michael and Lacey sued Kaiser for, among other things, breach of contract and medical malpractice. Kaiser filed a motion to compel arbitration, arguing that a group agreement entered into Kaiser and the EUTF was applicable to Michael when he signed the enrollment form. The group agreement contained an arbitration provision. The circuit court granted the motion to compel arbitration. The Supreme Court vacated the circuit court's orders, holding (1) the arbitration provision was unenforceable based on the lack of an underlying agreement between Kaiser and Michael to arbitrate; and (2) accordingly, Lacey was also not bound to arbitrate her claims in this case. View "Siopes v. Kaiser Found. Health Plan, Inc." on Justia Law

Plaintiffs, individually and as personal representatives of Makamae Ah Mook Sang's estate, filed a negligence action against defendants after Makamae died of acute alcohol intoxication after attending a party at defendants' home. At issue was whether a social host who invited a minor onto his or her property and then directly served to the minor owed a duty of care to prevent foreseeable injuries resulting from consumption of the alcohol, or to render or summon aid if injuries have occurred, while the minor remained on the property as a guest. The court held that a social host in the circumstances presented in this case owed a duty of care to a minor when the host has placed the minor in a position of peril and did not act to prevent foreseeable harm to the minor that could thereby result, and when the host did not act to aid the minor in the event that harm had occurred. Accordingly, the court vacated the circuit court's order and judgment, remanding for further proceedings. View "Sang v. Clark" on Justia Law

Aloha Tower Development Corporation filed a petition to expunge a deed restriction on a park requiring that it be preserved as a public park. Scenic Hawaii, Inc. subsequently intervened in the litigation. After a non-jury trial, the land court denied the petition. Scenic Hawaii filed a motion for attorneys' fees and costs under the private attorney general doctrine. The land court granted the request. The intermediate court of appeals (ICA) reversed the award of attorneys' fees. The Supreme Court vacated the judgment of the ICA and affirmed the final judgment of the land court, holding that the land court was correct in awarding attorneys' fees and costs to Scenic Hawaii under the private attorney general doctrine inasmuch as the three prongs of the private attorney general doctrine were satisfied in this case. View "In re Application of Honolulu Constr. & Draying Co., Ltd." on Justia Law

Petitioners, residents of Maui, challenged the Maui County Council's (MCC) passage of two bills related to the development of a residential community on 670 acres of land in Wailea (Wailea 670 project), arguing that MCC and its committee, the Land Use Committee (LUC) failed to satisfy the requirements of the State open meetings law, known as the Sunshine Law. Specifically, Petitioners claimed (1) the recessing and reconvening of two meetings without providing additional notice and opportunity for public oral testimony violated the Sunshine Law; and (2) the circulation of memoranda among the board membership outside a duly noticed meeting violated the Sunshine Law. The circuit court granted judgment in favor of Respondents, MCC, County of Maui, and the land developer. The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the LUC and MCC did not violate the Sunshine Law by reconvening the two meetings beyond a single continuance without posting a new agenda and without accepting public oral testimony at every reconvened meeting; and (2) the MCC violated the Sunshine Law by distributing written memoranda among its members outside of a duly noticed meeting, but the violation did not require invalidation of MCC's passage of the Wailea 670 bills. View "Kanahele v. Maui County Council" on Justia Law

After a jury trial, Defendant was convicted of theft in the second degree for allegedly offering to provide legal services and obtaining or exerting control over a retainer check by deception. Defendant appealed, arguing that the trial court erred in sua sponte failing to instruct the jury on the mistake of fact defense as to her conviction. Defendant cited to State v. Stenger for the proposition that if she was laboring under a mistake of fact that could negate the state of mind necessary to commit theft, the trial court was required sua sponte to instruct the jury on the mistake of fact defense. The intermediate court of appeals (ICA) agreed based on Stenger and vacated the conviction. The State appealed, requesting that the Supreme Court overrule Stenger. After clarifying Stenger's holding, the Court reversed the ICA and affirmed Defendant's conviction, holding that the trial court did not plainly err in omitting the mistake of fact jury instruction, as Defendant had not met her initial burden of adducing credible evidence of facts constituting the defense, and those facts were not supplied by the prosecution's witnesses. View "State v. Taylor" on Justia Law

Jasmine Fry, a twenty-two-year-old woman, died after entering into and becoming trapped in an exhaust duct above the food court in the Ala Moana Center (Ala Moana). Fry entered the duct by way of the building's rooftop. Fry's parents (Plaintiffs) sued Ala Moana, alleging various tort claims. The circuit court entered summary judgment in favor of Ala Moana on all claims. The intermediate court of appeals affirmed, concluding that Ala Moana did not owe Fry a legal duty under any theory of liability. The Supreme Court vacated in part and affirmed in part, holding (1) summary judgment was properly granted on Plaintiffs' general premises liability claims because Ala Moana owed no duty to a person not reasonably anticipated to be on the rooftop and because Fry's entry into the duct was not reasonably foreseeable; (2) genuine issues of fact existed as to whether Ala Moana breached its duty under the Restatement (Second) of Torts 338; and (3) genuine issues of fact existed as to whether Fry was a member of the public who entered the center in response to Ala Moana's invitation and, if so, whether Ala Moana breached its duties under the Restatement (Second) of Torts 314A(3). Remanded. View "Winfrey v. GGP Ala Moana LLC" on Justia Law

In 1971, Plaintiff began subleasing a half-acre parcel of land that was part of an undivided 1040-acre parcel of property (master parcel). Plaintiff and the master parcel's owner, Princeville Development Corporation, subsequently entered into a license agreement effective until 2003 that included an option to purchase and a right of first refusal. The agreement also contained a provision stating that any holding over after the expiration of the term of the agreement should be on the terms and conditions specified in the agreement. In 2005, the Corporation sold the master parcel to Princeville Prince Golf Course (PPGC). Plaintiff filed a complaint against the Corporation in 2005, praying for specific performance of the option to purchase clause. PPGC was substituted as Defendant. The circuit court dismissed Plaintiff's claim for specific performance, holding that the sale of the master parcel did not constitute a "decision to sell" the premises which would trigger Defendant's right of first refusal. The intermediate court of appeals (ICA) affirmed. The Supreme Court reversed, holding (1) Plaintiff's right of first refusal continued into the holdover period; and (2) the right of first refusal was triggered by the Corporation's decision to sell the master parcel in 2005. Remanded. View "Kutkowski v. Princeville Prince Golf Course, LLC" on Justia Law

Petitioner pleaded no contest to one count of assault in the first degree and one count of kidnapping as a class B felony. In its first minimum term order, the Hawaii Paroling Authority (HPA) set Petitioner's minimum term of imprisonment at eighteen months for each count. After Petitioner had been imprisoned for more than six months, the HPA held a second hearing to allow Complainant to testify. At the conclusion of the hearing, the HPA imposed a minimum term of five years imprisonment on each count. Petitioner subsequently filed a petition for post-conviction relief, arguing that the HPA violated his constitutional rights to due process and equal protection by reopening his minimum term hearing and by subsequently increasing his minimum term. The circuit court dismissed Petitioner's petition. Petitioner appealed, arguing, inter alia, that the HPA wrongfully withheld evidence from him prior to the second hearing. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA judgment and circuit court order, holding that the ICA erred in concluding that Petitioner waived his due process claim relating to the HPA's nondisclosure of adverse materials in Petitioner's HPA file. Remanded for an evidentiary hearing. View "De La Garza v. State " on Justia Law

Plaintiff brought this suit against the City and County of Honolulu and the State, challenging the approval of a rail project and arguing that state law required that an archaeological inventory survey be completed prior to any approval or commencement of the project. The circuit court granted summary judgment in favor of the City and State on all of Plaintiff's claims. The Supreme Court vacated the circuit court's judgment on Plaintiff's claims that challenged the rail project under Haw. Rev. Stat. 6E and remanded. Plaintiff subsequently requested that the Supreme Court award $255,158 in attorney's fees and $2,510 in costs against the City and State for work performed in the trial court. The Supreme Court (1) granted Plaintiff's request for appellate attorney's fees and costs against the City in the amount of $41,192 in attorney's fees and $343 in costs; (2) and denied Plaintiff's request for trial level fees and costs without prejudice, as Plaintiff's request for fees and costs attributable to work performed at the trial level was more properly within the trial court's discretion. View "Kaleikini v. Yoshioka" on Justia Law