Justia Hawaii Supreme Court Opinion Summaries

Aaron and Bonnie Kakinami were divorced pursuant to a a divorce decree that reserved property division. Pursuant to a supplemental divorce decree, the family court classified a gift and several inheritances that Bonnie received during the marriage as marital separate property and awarded Bonnie one hundred percent of that property. After Aaron filed a notice of appeal, the family court issued an order compelling Aaron to pay Bonnie her net share of the marital residence. The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed, holding (1) the ICA erred in stating that the family court had the authority to award marital separate property to a non-owning spouse, as marital separate property remains non-divisible under the framework set forth in Hussey v. Hussey; (2) the family court did not abuse its discretion when it adhered to the partnership model of property division in dividing the parties' marital partnership property, because the existence of an inheritance, without more, does not mandate deviation; and (3) the family court had jurisdiction when it issued its post-decree order because the order enforced a preexisting obligation. View "Kakinami v. Kakinami" on Justia Law

After a jury trial, Petitioner Glenn Keohokapu was convicted of manslaughter and sentenced to an extended term of life imprisonment with the possibility of parole. The intermediate court of appeals (ICA) affirmed. The Supreme Court affirmed the judgment of conviction, holding that the process by which the jury was selected for Petitioner's trial did not result in substantial prejudice to Petitioner notwithstanding the pretrial publicity to which some jurors were exposed. The Court, however, vacated Petitioner's extended term sentence, holding that, as to the extended sentencing proceedings, (1) where the jury must determined whether an extended term of imprisonment is necessary for the protection of the public, it is error to instruct the jury that the extended term sentence includes the possibility of parole; (2) in this case it was error to admit the statement of one of the witnesses during the sentencing phase as past recollection recorded; and (3) these errors were not harmless beyond a reasonable doubt. View "State v. Keohokapu" on Justia Law

After his divorce from Respondent, Petitioner filed a motion to set aside the divorce decree, which granted the parties a divorce and awarded child custody. The family court denied the motion. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment of the ICA in part, insofar as it held the court properly awarded Respondent the copyrights and vacated the portion of the divorce decree that awarded Respondent all ownership interest in copyrights held in Petitioner's name, holding (1) the family court did not abuse its discretion in denying Petitioner's motion, as Petitioner had notice that his failure to appear at a scheduled settlement conference would result in default, and the court acknowledged that Petitioner's motion was for Hawaii Fam. Ct. R. 60(b) relief, although Petitioner had failed to cite rule 60(b) in support of the motion; and (2) the court abused its discretion in declining to set aside that part of the divorce decree that transferred Petitioner's entire ownership interest in the copyrights to Respondent in violation of federal law. The Court affirmed the divorce decree in all other respects. Remanded for a determination of the economic interest in the copyrights to which Respondent was entitled. View "Berry v. Berry" on Justia Law

Petitioner Alohacare bid for a health and human services contract under Haw. Rev. Stat. 103F but was denied the contract by Respondent, the Department of Human Services. Petitioner protested and later appealed. The lower courts dismissed Petitioner's appeal for lack of jurisdiction, finding that Petitioner was not entitled to judicial review. The Supreme Court vacated the judgment of the lower courts, holding (1) Petitioner may not appeal the denial of a contract award by Respondent under the procedures set forth in Haw. Rev. Stat. 103D that afford judicial review for bidders denied protests; (2) however, chapter 103F does not prohibit judicial review of the administrative denial of such matters, and review may be afforded under Haw. Rev. Stat. 632; (3) review and denial of a bidder's protest by Respondent as the purchasing agency and subsequent denial of a request for reconsideration by the chief procurement officer housed in a different executive agency do not assuage separation of powers concerns because review is accomplished only in the executive branch of government; and (4) Petitioner was not denied due process or equal protection by chapter 103F, inasmuch as judicial review may be obtained by way of a declaratory judgment action. Remanded. View "Alohacare v. Dep't of Human Servs." on Justia Law

State Department of Education (DOE) issued a request for proposals to provide health and human services under contracts pursuant to Haw. Rev. Stat. 103F. After the DOE rejected the proposal of Petitioner Alaka'i Na Keiki, Inc., Petitioner brought an action against the DOE. The circuit court granted summary judgment in favor of the DOE. The intermediate court of appeals affirmed, concluding that chapter 103F does not allow for judicial review. The Supreme Court vacated the judgment of the lower courts, holding that the DOE's decisions to reject such proposals were subject to judicial review. The Court then held (1) as construed, chapter 103F was not unconstitutional for violating the separation of powers doctrine; (2) Petitioner's request for a declaratory judgment was moot to the extent the subject contracts had been awarded and their terms expired; (3) Petitioner's claim for negligence by the DOE was barred under the State Tort Liability Act; and (4) Petitioner's claim for injunctive relief, premised on the DOE's alleged faulty administration of the contract process, was moot inasmuch as the Court interpreted such process in chapter 103F as subject to judicial review. Remanded. View "Alaka'i Na Keiki, Inc. v. Matayoshi " on Justia Law

Petitioner Less Schnabel allegedly caused the death of decedent by one punch. After a jury trial, Petitioner was found guilty of manslaughter and sentenced to twenty years of imprisonment. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment of the ICA, holding (1) the ICA gravely erred in affirming the ruling of the circuit court that the State would be allowed to introduce evidence from the prior juvenile proceedings of Petitioner if Petitioner testified on cross-examination in the instant case that he did not know a single punch could cause the death of a person; and (2) the statement of the deputy prosecuting attorney to the jury during closing arguments not to "get too caught up in the mumbo jumbo of all the words [of the jury instructions,]" among other statements, infringed on Petitioner's right to have the case against him proven beyond a reasonable doubt. Remanded. View "State v. Schnabel" on Justia Law

Defendant Lloyd Pratt received three citations when he was found residing in a closed area of a state park. Pratt filed a motion to dismiss the charges, asserting as a defense that his activities were constitutionally-protected native Hawaiian practices, and citing State v. Hanapi, which defined the scope in the criminal context of the legal privilege for native Hawaiians to engage in customary or traditional native Hawaiian practices when such practices conflict with State statute or regulations. The district court denied the motion, held trial, and found Pratt guilty on all three charges. The intermediate court of appeals (ICA) affirmed. The Supreme Court granted certiorari to clarify the law surrounding the assertion of native Hawaiian rights as a defense in criminal cases. The Court affirmed, holding (1) the courts below did not err in utilizing a balancing test in this case; (2) in balancing interests, the court must consider the totality of the circumstances; and (3) under the totality of the circumstances test, Pratt's convictions must be affirmed. View "State v. Pratt" on Justia Law

Petitioner Patrick Ho was convicted of first degree sexual assault and third degree sexual assault. Petitioner appealed, arguing (1) the circuit court's refusal to disqualify two jurors who were sexually assaulted as teenagers compelled him to use two of his three peremptories to remove the jurors from the jury panel, and (2) the court erroneously removed two other jurors for cause at Respondent's request after Petitioner exercised all of his peremptories, based on identical grounds urged by the State before the parties exercised their peremptory challenges. The Supreme Court vacated the judgment of conviction and sentence, holding that under the circumstances here, the circuit court plainly erred when during jury selection it removed two jurors for cause on the motion of the State after the jury panel already had been passed for cause and Petitioner and the State had already exhausted their peremptory challenges. Remanded for a new trial. View "State v. Ho" on Justia Law

In this case the Supreme Court was presented with the question of whether the political question doctrine barred Hawaiian Homes Commission Act (HHCA) beneficiaries from using the Hawaiian Constitution's "sufficient sums" provision to demand more legislative funding of the Department of Hawaiian Home Lands (DHHL) when that provision provided no guidance as to how quickly homesteads must be developed. The Supreme Court held (1) judicial determination of "sufficient sums" as to the purpose of DHHL's administrative and operating expenses is not barred as a nonjusticiable political question, and the intermediate court of appeals (ICA) did not err in so holding; but (2) the political question bars judicial determination of what would constitute "sufficient sums" for the purposes of (a) development of home, agriculture, farm and ranch lots, (b) home, agriculture, aquaculture, farm and ranch loans, and (c) rehabilitation projects, and the ICA erred in concluding otherwise. View "Nelson v. Hawaiian Homes Comm'n" on Justia Law

This case arose from a fatal car accident that occurred on a county highway, which resulted in the death of Shawn Kaikala. Petitioners, several individuals related to Kaikala, filed a civil complaint against the State, asserting claims for negligence and wrongful death. The circuit court entered judgment in favor of the State. Petitioners filed a notice of appeal after the circuit court extended the deadline. The intermediate court of appeals (ICA) concluded (1) absent a finding of "good cause," it was improper for the circuit court to grant the deadline extension, and (2) therefore, the ICA did not have jurisdiction to hear the appeal because Petitioners' notice of appeal was untimely. The Supreme Court vacated the ICA's dismissal of Petitioners' appeal, holding that based upon the specific, unique factual circumstances in this case, the ICA erred by concluding that it did not have jurisdiction to hear Petitioners' appeal. Remanded for consideration on the merits. View "Cabral v. State" on Justia Law