Justia Hawaii Supreme Court Opinion Summaries

In 2009, the State charged Petitioner with the offense of accident involving death or serious bodily injury in violation of Haw. Rev. Stat. 291C-12. After a trial, the court found Petitioner guilty as charged. The intermediate court of appeals (ICA) affirmed Petitioner's conviction. Petitioner appealed, contending that the indictment was fatally defective, a challenge that was raised for the first time on appeal. The Supreme Court vacated the judgment of the ICA and dismissed the case without prejudice, holding (1) the indictment against Petitioner failed to allege the requirements of Haw. Rev. Stat. 291C-14(a) and (b); and (2) under the circumstances of this case, Petitioner was prejudiced by this defect in the indictment. View "State v. Ngo" on Justia Law

After a jury trial, Petitioner was convicted by the district court of committing assault in the third degree in the course of a mutual affray. The intermediate court of appeals (ICA) affirmed Petitioner's conviction but vacated his sentence and remanded for resentencing. The Supreme Court vacated Petitioner's conviction, holding (1) Petitioner's argument that he was immune from the district court's jurisdiction because of the legitimacy of the Kingdom government was without merit; but (2) the district court violated Petitioner's right to a jury trial because Petitioner demanded a jury trial, and his departure from the courtroom during his trial did not operate as an implied waiver of this right. In addition, the Court held that there was sufficient evidence to negate Petitioner's claim of self-defense. View "State v. Kaulia" on Justia Law

Plaintiff was the Democratic party candidate for the office of state representative, district 47, in the November 6, 2012 general election. After the election results showed Plaintiff had lost the election, Plaintiff challenged the results by filing a complaint in the Supreme Court against her opponent Richard Fale, BYU-Hawai'i, the Polynesia Cultural Center, Hawai'i Reserves, Inc., and a newspaper writer, alleging that Fale received more votes because several defendants conspired to throw the electoral process. The Supreme Court dismissed the complaint, holding that Plaintiff could prove no set of facts entitling her to relief, as none of Plaintiff's allegations related to her perceived inequities in the campaign process satisfied her burden of demonstrating errors that would change the outcome of the election for house of representatives, district 47. View "Beirne v. Fale " on Justia Law

Respondents initiated an action against Petitioner and others based on an investigation conducted by the Office of Consumer Protection. Petitioner subsequently filed the present action against Respondents, alleging that Respondents were liable for malicious prosecution, negligent investigation, negligent failure to train and/or supervise, and punitive damages arising from the initiation and maintenance of the earlier action. The court found in favor of Respondents. The intermediate court of appeals affirmed. The Supreme Court affirmed in part and vacated in part the trial court's amended final judgment, holding (1) a plaintiff may bring an action in tort for the maintenance of a malicious prosecution as well as for the initiation of a malicious prosecution; (2) the trial court properly granted summary judgment for Respondents on Plaintiff's claims of maintenance of a malicious prosecution and initiation of a malicious prosecution; but (3) the court erred in failing to state its rationale for granting in part Petitioner's motion for review and/or to set aside taxation of costs. Remanded. View "Arquette v. State" on Justia Law

After a second jury trial, Petitioner was found guilty of attempted sexual assault in the first degree, kidnapping-no voluntary release, attempted assault in the third degree, and assault in the third degree. The Supreme Court (1) affirmed Petitioner's convictions for assault in the third degree; (2) vacated Petitioner's convictions for attempted sexual assault in the first degree and kidnapping; and (3) vacated the court's sentence on Petitioner's convictions for assault in the third degree, holding that the circuit court erred by permitting the State to introduce evidence of acts allegedly committed by Petitioner for which a jury had acquitted him in the prior trial because the evidence violated the principle of collateral estoppel embodied in the double jeopardy clause of the Hawai'i Constitution. View "State v. Mundon" on Justia Law

Defendant was charged with excessive speeding in violation of Haw. Rev. Stat. 291C-105(a). After the charge was read, Defendant moved to dismiss the charge, arguing that it failed to state the requisite state of mind under Haw. Rev. Stat. 702-204. The court denied Defendant's motion, ruling that when a statute does not expressly set forth the culpable state of mind, but rather imports the mens rea element from Haw. Rev. Stat. 702-212 that obviated the need of the State to articulate a state of mind. The district court subsequently convicted Defendant of the charge. The Supreme Court vacated the judgment and instructed the district court to dismiss the charge without prejudice, holding (1) the offense of driving at an excessive speed is not a strict liability offense and requires proof that the defendant acted intentionally, knowingly, or recklessly, an thus, the requisite states of mind must be alleged in a charge of this offense; (2) the section 291C-105(a) charge against Defendant failed to allege the requisite states of mind; and (3) the State also failed to lay an adequate foundation to admit a laser instrument reading of Defendant's vehicle's speed into evidence. View "State v. Gonzalez" on Justia Law

Del Monte Fresh Produce Company decided to cease growing pineapples at its plantation on O'ahu. The company's subsidiary, Del Monte Fresh Produce (Hawaii), Inc, subsequently bargained with the International Longshore and Warehouse Union, Local 142, with regard to the effects of that decision on Del Monte employees in Hawaii. The Union believed the company was not negotiating in good faith and filed a complaint with the Hawai'i Labor Relations Board alleging that Del Monte had engaged in unfair labor practices. The Hawaii Labor Relations Board (HLRB) entered an order concluding that Del Monte failed to bargain in good faith. The circuit court and intermediate court of appeals affirmed. The Supreme Court affirmed, holding that the HLRB did not clearly err in finding Del Monte engaged in bad faith bargaining, because there was substantial evidence that the totality of Del Monte's conduct did not evince a present intention to find a basis for agreement and a sincere effort to reach common ground. View "Del Monte Fresh Produce (Haw.), Inc. v. Int'l Longshore & Warehouse Union, Local 142" on Justia Law

While traveling to California to meet his obligations in a pending matter in that state's courts, Petitioner, who was on release in an unrelated criminal proceeding in the circuit court, was arrested at the Honolulu International Airport. Petitioner's arrest led to the drug charge in the instant court proceedings. Petitioner posted bail and was released from custody. Petitioner proceeded to California, where he was held in custody. Petitioner was not present for his arraignment because he was in custody in California. The circuit filed a a bail forfeiture judgment. The circuit court later denied Petitioner's motion to set aside bail forfeiture and for return of bail. The Supreme Court vacated the judgment of the intermediate court of appeals and held the that circuit court erred in denying Petitioner's motion because, under the circumstances, Petitioner's incarceration in California established good cause for his failure to appear at his arraignment, and thus for why the bail forfeiture judgment should not be executed. View "State v. Diaz" on Justia Law

Petitioner was charged with promoting a dangerous drug in the third degree. Prior to trial, Petitioner filed a motion to suppress seeking to preclude the State from introducing methamphetamine obtained during a warrantless search of Petitioner's pockets. The circuit court suppressed the evidence. The intermediate court of appeals (ICA) vacated the suppression order and remanded to the court for entry of its findings and conclusions regarding whether the State met its burden of establishing by clear and convincing evidence that the methamphetamine would have been inevitably discovered by lawful means pursuant to State v. Lopez. On remand, the court again ordered the evidence suppressed. The ICA ordered the second suppression order vacated and the case remanded for trial, concluding that the circuit court did not make factual findings regarding the events relevant to the issue of inevitable discovery. The Supreme Court vacated the judgment of the ICA and affirmed the circuit court's judgment, holding that the circuit court was not wrong in holding that the State failed to present clear and convincing evidence that the methamphetamine would have inevitably been discovered. View "State v. Rodrigues" on Justia Law

Paulette Kaleikini is a native Hawaiian who engages in traditional and customary practices, including the protection of native Hawaiian burial remains. Kaleikini brought suit against the City and County of Honolulu and the State of Hawai'i, challenging the approval of the Honolulu High-Capacity Transit Corridor Project. Kaleikini argued that the rail project should be enjoined until an archaeological inventory survey, which identifies and documents archaeological historic properties and burial sites in the project area, is completed for all four phases of the project. The City moved to dismiss Kaleikini’s complaint and/or for summary judgment, and the State joined in the motion. The City acknowledged that an archaeological inventory survey was required for each phase of the rail project. The City and State contended that as long as an archeological inventory survey had been completed for a particular phase, construction could begin on that part of the project even if the surveys for the other phases had not yet been completed. The Circuit Court of the First Circuit granted summary judgment in favor of the City and State on all of Kaleikini’s claims. Kaleikini appealed the circuit court’s final judgment in favor of the City and the State. Upon review, the Supreme Court concluded that the City and State failed to comply with State law pertaining to the surveys and its implementing rules when it concurred in the rail project prior to the completion of the required archaeological inventory survey for the entire project. The City similarly failed to comply with State law and its implementing rules by granting a special management area permit for the rail project and by commencing construction prior to the completion of the historic preservation review process. Accordingly, the Supreme Court vacated the circuit court’s judgment on Counts 1 through 4 of Kaleikini’s complaint and remanded the case to the circuit court for further proceedings on those counts. The Court affirmed the circuit court’s judgment in all other respects. View "Kalekini v. Yoshioka" on Justia Law