Justia Hawaii Supreme Court Opinion Summaries

Respondents, the Castro family, executed a mortgage encumbering their property that was assigned to Petitioner, U.S. Bank. When the Castros defaulted on their loan, U.S. Bank purchased the property at a foreclosure auction. Because the Castros failed to vacate the property as instructed, U.S. bank filed a two complaints for summary possession and ejectment against the Castros. The district court entered a judgment for possession and a writ of possession in favor of U.S. Bank and a separate order granting summary judgment for U.S. Bank. The intermediate court of appeals vacated the district court's judgment, concluding that the district court lacked jurisdiction over the case because the action was one in which title to real estate would come into question. The Supreme Court reversed, holding that the district court properly exercised subject matter jurisdiction over the case because the Castros failed to demonstrate the action was one in which title to the subject property would come into question. View "U.S. Bank Nat'l Ass'n v. Castro" on Justia Law

Petitioner posted bond for Defendant after Defendant was charged with several crimes. When Defendant failed to appear for trial, a judgment and order of forfeiture of bail bond was filed. Petitioner's motion was denied. Petitioner subsequently filed two successive motions for relief from forfeiture of bail bond pursuant to Haw. R. Civ. P. 7 and 60(b). The circuit court denied the motions. Petitioner appealed the denial of his third motion, which was dismissed as untimely. The intermediate court of appeals affirmed, holding (1) the Hawaii Rules of Civil procedure (HRCP) do not apply in bond forfeiture proceedings; and (2) Haw. Rev. Stat. 804-51 establishes the exclusive means to seek relief from a judgment of forfeiture. The Supreme Court affirmed, holding (1) the HRCP do not apply to bond forfeiture proceedings; (2) the statement in Haw. Rev. Stat. 804-14 that a surety may recover its bond at any time by surrendering the defendant is qualified by section 804-51, which provides that once the court enters a judgment of forfeiture, a surety is entitled to relief only by filing a motion within thirty days demonstrating good cause for setting the judgment of forfeiture aside; and (3) Petitioner's last motion was therefore untimely. View "State v. Vaimili" on Justia Law

After a jury trial, Defendant was convicted of assault in the second degree, terroristic threatening in the second degree, and terroristic threatening in the first degree. Defendant appealed, arguing that the circuit court erred in denying his request for the written transcripts or the DVD video recordings of his codefendant's trial. The intermediate court of appeals affirmed. The Supreme Court vacated the lower courts' judgments, holding that Defendant demonstrated that the requested transcripts or DVD video recordings were necessary for an effective defense where the charges against Defendant and his codefendant arose from the same incident and involved identical facts, and the same key witness testified against Defendant and his codefendant at their respective trials. Remanded for a new trial. View "State v. Scott" on Justia Law

Petitioner was orally arraigned and charged with excessive speeding in violation of Haw. Rev. Stat. 291C-105(a)(1). After a trial, the trial court found Petitioner guilty as charged. Petitioner appealed, and the Intermediate Court of Appeals (ICA) affirmed. Petitioner appealed, arguing that the oral charge failed to allege the required intentional, knowing, and reckless states of mind and that the oral charge was therefore defective. The Supreme Court vacated the ICA's judgment, holding (1) because the charge against Petitioner did not allege that Petitioner acted intentionally, knowingly, or recklessly, the charge failed to allege the requisite state of mind; and (2) the State failed to lay an adequate foundation to admit the laser gun reading of Petitioner's vehicle's speed into evidence during trial. Remanded. View "State v. Apollonio" on Justia Law

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