District Court, D. Hawaii — appointed by Gerald Ford
Sotomura v. County of Hawaii
District Court, D. Hawaii · 1978-10-16 · cited 4×
This case concerns an eminent domain proceeding by the County of Hawaii to acquire registered seashore land for a public beach park, focusing on the proper location of the seaward boundary after alleged erosion. The Hawaii Supreme Court held that the owners lost title to the portion of the lot seaward of the vegetation line due to erosion, applying the Ashford precedent to redefine the high-water mark and thereby reducing the compensation owed for the taking. The federal district court reviewed whether this ruling improperly altered the boundaries fixed by the original land court registration decree, which had used the seaweed line as the monument. The core reasoning centers on the conclusive effect of land court judgments, the distinction between registered and unregistered land, and the impact of changing the boundary marker on the owners' property rights.
property
Christensen v. Northwest Airlines, Inc.
District Court, D. Hawaii · 1978-08-23 · cited 3×
The case involved a passenger who was denied boarding on a Northwest Airlines flight due to overbooking despite a confirmed reservation, leading to alternative arrangements and an arrival about 1 hour and 40 minutes later than scheduled; she sued for general and punitive damages alleging misrepresentation, emotional distress, and other harms. The court granted the airline's motion for summary judgment. It reasoned that there was no viable federal claim under 49 U.S.C. § 1374(b) due to lack of evidence of undue preference or discrimination, that denied boarding compensation rules did not support liability here, and that diversity jurisdiction under 28 U.S.C. § 1332 was absent because the damages sought lacked a factual basis, were not claimed in good faith, and fell below the jurisdictional threshold.
business & regulatoryprocedure
Kupau v. Yamamoto
District Court, D. Hawaii · 1978-08-16 · cited 4×
This case involves a dispute over the installation of a union officer after an election in Local No. 745 of the United Brotherhood of Carpenters and Joiners of America. Plaintiffs claimed that defendants violated their rights under the Labor-Management Reporting and Disclosure Act by refusing to install the elected candidate, Kupau, based on a post-election eligibility determination by the union's General President. The court held that it had jurisdiction under Title I of the Act because the claims involved discriminatory post-election conduct rather than a challenge to the election itself. The court granted the plaintiffs' motion for a preliminary injunction, ordering Kupau's installation, and denied the defendants' motion to dismiss, finding that plaintiffs were likely to succeed on the merits and would suffer irreparable harm without relief.
labor & employmentelectionscivil rights
Wakinekona v. Olim
District Court, D. Hawaii · 1978-06-08 · cited 6×
In Wakinekona v. Olim, a Hawaii state prisoner serving life without parole sued after being transferred to Folsom State Prison in California following a program classification hearing, claiming the hearing committee was biased and that the process violated due process under the Fifth and Fourteenth Amendments as well as state regulations and law. The district court initially ruled that state regulations created a protected liberty interest requiring impartial decisionmakers but reconsidered after First Circuit decisions in Lombardo v. Meachum and Four Unnamed Inmates. The court concluded that Hawaii statutes and regulations granted prison officials broad discretion over transfers without imposing standards that would create a liberty interest, so due process did not apply and the federal claims were dismissed under Rule 12(b)(6); the remaining state-law claims were also dismissed for lack of pendent jurisdiction.
criminal lawcivil rightsprocedure
Aluli v. Brown
District Court, D. Hawaii · 1977-09-15 · cited 19×
In Aluli v. Brown, plaintiffs sued to halt the U.S. Navy's live and inert ordnance bombing on Kahoolawe Island, Hawaii, claiming violations of the National Environmental Policy Act for failing to submit an updated environmental impact statement with funding requests and of Executive Order 11593 and related regulations for not adequately surveying, inventorying, or nominating historic and archaeological sites for the National Register of Historic Places. The district court granted partial summary judgment to plaintiffs on the historic preservation claim (Claim Nine) and ordered the Navy to comply with EO 11593 and 36 C.F.R. Part 800 by cooperating with state surveys, nominating qualifying sites without awaiting full-island completion, and referring the island for an eligibility determination; it also required submission of a revised EIS that quantifies all archaeological sites. The court rejected the Navy's arguments that the NHPA did not apply absent a prior Secretary of the Interior eligibility finding and that internal Navy instructions were unenforceable, reasoning that EO 11593 imposes affirmative duties on federal agencies to protect potential historic properties and that the Navy must request an eligibility opinion when sites appear to qualify. The court permitted continued bombing activities subject to these compliance obligations.
environmentfederal power
Jensen v. Yonamine
District Court, D. Hawaii · 1977-08-22 · cited 3×
This case involves public school teachers in Hawaii who are not members of the teachers' union (HSTA) and who sued to challenge the constitutionality of mandatory service fees deducted from their wages under HRS § 89-4 and paid to the union, alleging that portions of the fees were used for political purposes unrelated to collective bargaining in violation of their First, Ninth, Tenth, and Fourteenth Amendment rights as well as state constitutional provisions. The plaintiffs sought damages, declaratory relief, and an accounting, framing the claims under 42 U.S.C. §§ 1983, 1985(3), and 1986. The court held that it had subject matter jurisdiction over the federal claims and pendent jurisdiction over the state claims, but dismissed the § 1985(3) claim because the complaint failed to allege any conspiracy among the defendants. Relying on the Supreme Court's intervening decision in Abood v. Detroit Board of Education, the court recognized that service fees are permissible for bargaining-related activities but not for political expenditures without affirmative consent, yet it concluded that abstention under the Pullman doctrine was appropriate due to ambiguities in the state statute that could be clarified by Hawaii courts and that would potentially resolve or narrow the federal constitutional questions.
labor & employmentcivil rightsfree speechfederal power