Justia Hawaii Supreme Court Opinion Summaries

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

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