Justia Hawaii Supreme Court Opinion Summaries

Defendant was found guilty of several drug-related offenses. At his sentencing hearing, Defendant was represented by a court-appointed deputy public defender. Privately retained counsel also appeared on behalf of Defendant and sought to substitute for the deputy public defender. Defendant's privately retained counsel requested a continuance to prepare. The circuit court denied Defendant's motion to substitution of counsel and a continuance as untimely. The court then sentenced Defendant to a term of imprisonment. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the ICA's and circuit court's judgment, holding that the circuit court violated Defendant's constitutional right to counsel of his choice when it denied his motion for substitution of counsel and a continuance of the sentencing hearing, as the court did not properly balance Defendant's right to counsel of his choice against countervailing government interests. Remanded. View "State v. Cramer" on Justia Law

Plaintiffs brought a negligence action against the City for damages arising from an accident in which William Kobashigawa was truck and killed while crossing a mid-block crosswalk. The jury returned a verdict in favor of the City, finding the City was not negligent. The intermediate court of appeals (ICA) vacated the jury verdict and remanded for a new trial, concluding that the circuit court plainly erred in giving a cautionary instruction that permitted the jury to consider evidence of Plaintiffs' motive in filing suit and in allowing the City to comment on that motive in its closing argument. The Supreme Court affirmed as modified, holding (1) the ICA correctly found that the circuit court's cautionary instruction regarding motive was a prejudicially erroneous statement of the law; but (2) the ICA incorrectly found that Plaintiffs failed to preserve their objections to the admission of irrelevant evidence concerning their motive in filing suit and that such failure required it to resort to plain error review. View "Kobashigawa v. Silva" on Justia Law

The State contracted with a general contractor (Contractor) to complete the renovation of an elementary school. The project required extensive glazing work, specifically, the fabrication and installation of jalousie windows. Contractor held a C-5 specialty license in cabinet, millwork, and carpentry remodeling and repairs, but it did not hold a specialty glazing license. The Department of Commerce and Consumer Affairs' (DCCA) Contractors License Board (Board) determined that Contractor could complete the jalousie window work pursuant to its C-5 license. Specifically, the Board determined that the jalousie window work qualified as "incidental and supplemental" to the remodeling and repair work authorized under Contractor's C-5 license. The circuit court and intermediate court of appeals affirmed. The Supreme Court vacated the judgments of the lower courts, holding that because the Board did not consider the cost and extent of the jalousie window work when determining if that work qualified as "incidental and supplemental" to the project, the Board's interpretation of the "incidental and supplemental" exception was contrary to law and to the primary purpose of the legislation regarding contractor licensing. Remanded. View "Dist. Council 50 of Int'l Union of Painters & Allied Trades v. Lopez" on Justia Law

Appellant, a medical doctor, challenged the partial denial of personal injury protection benefits after treating a patient insured by Appellee. While Appellant's request for an administrative hearing was pending in the Insurance Division of the State Department of Commerce and Consumer Affairs, the patient's available benefits under her policy were exhausted on account of payments to Appellant and other medical providers. Because of the exhaustion, the Insurance Division dismissed Appellant's claim. The circuit court and intermediate court of appeals (ICA) affirmed. The circuit court also denied Appellant's request for attorney's fees and costs under Haw. Rev. Stat. 431:10C-211(a), which allows fees and costs to be awarded even when a party does not prevail on its claim for benefits, finding Appellant's pursuit of the benefits to be unreasonable. The ICA affirmed. Appellant appealed the denial of attorney's fees. The Supreme Court vacated the ICA's judgment and the circuit court's final judgment, holding that the circuit court and ICA erred in concluding that Appellant's claim was unreasonable due to exhaustion of benefits where Plaintiff had made his claim prior to that exhaustion. Remanded. View "Jou v. Schmidt" on Justia Law

Defendant was charged with one count of Unauthorized Possession of Confidential Personal Information (UPCPI) for identifying himself to a police officer during two traffic stops by using the name and address of his former neighbor. Defendant moved to dismiss the charge as a de minimis violation of the UPCPI statute on the ground that his conduct did not actually cause or threaten the harm sought to be prevented by the statute. The circuit court dismissed the charge. The intermediate court of appeals (ICA) vacated the circuit court's dismissal order on the ground that the circuit court had not been presented with all of the relevant circumstances surrounding the offense as required under State v. Rapozo. The Supreme Court affirmed but for different reasons, holding that the circuit court abused its discretion in concluding that Defendant's conduct constituted a de minimis violation of the UPCPI statute because Defendant's conduct actually caused or threatened the harm sought to be prevented by the statute. Remanded. View "State v. Pacquing" on Justia Law

After a jury trial, Defendant was convicted of manslaughter and carrying or use of a firearm in the commission of a felony. The intermediate court of appeals affirmed. The Supreme Court affirmed, holding (1) the circuit court did no abuse its discretion in denying Defendant's motion to dismiss the amended complaint; (2) the circuit court did not plainly err in allowing the testimony of two witnesses without formally qualifying them as expert witnesses and substituting the words "opinion testimony" for the word "expert" in the jury instruction; (3) the circuit court did not plainly err in instructing the jury on self-defense, in failing to sua sponte instruct the jury on defense of property, or in failing to provide a cautionary instruction on the use of medical marijuana; and (4) Defendant failed to establish that his trial counsel was ineffective. View "State v. Metcalfe" on Justia Law

Plaintiffs granted Eastern Savings Bank, FSB (Eastern) a mortgage on property as security for a loan. Plaintiffs defaulted on the loan, and Eastern filed an action to foreclose the mortgage. The circuit court foreclosed on the mortgage, and a public auction was held to sell the property. Eastern purchased the property and filed a motion for confirmation of sale. Plaintiffs subsequently filed a complaint in the U.S. district court seeking a declaratory judgment that the promissory note and mortgage had been timely cancelled pursuant to the federal Trust-in-Lending Act (TILA). The circuit court took judicial notice of Plaintiffs' pending federal case but declined to stay confirmation of the foreclosure sale in the meantime. Thereafter, the circuit court concluded Plaintiffs' pending TILA case did not bar confirmation of the sale of the property, confirmed the sale of the property to Eastern, and entered a deficiency judgment against Plaintiffs. The Supreme Court affirmed, holding that res judicata principles prohibit a debtor from asserting TILA rescission rights after a foreclosure judgment has become final, despite the rescission attempt being held within the time limit provided by TILA. View "E. Savings Bank, FSB v. Esteban" on Justia Law

The State charged Defendant with violating Haw. Rev. Stat. 291E-61(a)(1) and/or (a)(3) for operating a vehicle under the influence of an intoxicant (OVUII), but the complaint did not allege mens rea. During trial, Defendant moved for a judgment of acquittal and to strike all testimony about breath alcohol content. The district court interpreted this statement as a motion for judgment of acquittal as to section 291E-61(a)(3). The district court granted the motion and subsequently found Defendant guilty of violating section 291E-61(a)(1) only. The intermediate court of appeals (ICA) instructed the district court to dismiss without prejudice the portion of the complaint alleging a violation of section 291E-61(a)(1) because the charge was deficient for failing to allege mens rea. At issue on appeal was whether double jeopardy barred Defendant's re-prosecution for violating section 291E-61. The Supreme Court affirmed, holding (1) the collateral estoppel principle prohibited the State from re-litigating breath alcohol content, whether in a re-prosecution of Defendant on the section 291E-61(a)(3) method of proof, or as part of the State's evidence in a subsequent trial on the section 291E-61(a)(1) method of proof; and (2) collateral estoppel would not prohibit the State from re-charging Defendant on the section 291E-61(a)(1) method of proof. View "State v. Spearman" on Justia Law

Petitioner, an inmate, submitted a petition for a writ of mandamus seeking an order directing the Director of the Department of Public Safety (DPS) to approve dental treatment, teeth cleaning, a root canal, a cavity fix, cancer treatment, and treatment for concussion for brain trauma. The Supreme Court declined to grant the requested relief, as (1) Petitioner failed to demonstrate that DPS was purposefully ignoring or failing to respond to his dental or medical needs; and (2) the documents attached to the petition demonstrated that DPS provided Petitioner medical and dental care within the purview of the State's services, apprised Petitioner of the option to seek outside care for services not covered by the State, and offered services for pain relief. View "Tierney v. Sakai " on Justia Law

Plaintiff sued Dentist, claiming that Dentist had negligently provided him with orthodontic care. Dentist moved for summary judgment. On the day before the hearing, Plaintiff's counsel submitted a faxed copy of an expert affidavit stating that Dentist did not meet the standard of care. The circuit court struck Plaintiff's affidavit because it was a faxed copy and not an original and granted summary judgment in favor of Dentist. The intermediate court of appeals (ICA) vacated the circuit court's final judgment and remanded, determining that Dentist failed to satisfy his initial burden as the summary judgment movant and that Plaintiff did not have adequate time to conduct discovery. The Supreme Court affirmed, holding that the circuit court erred in granting summary judgment since Doctor did not satisfy his initial burden of production. The Court also clarified that Haw. R. Civ. P. 56(f) is the proper procedure to request and obtain additional time to respond to a motion for summary judgment that is filed prior to the discovery deadline. View "Ralston v. Yim" on Justia Law