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Feliciano v. City and County of Honolulu

Citations: 611 P.2d 989; 62 Haw. 88; 1980 Haw. LEXIS 154Docket: NO. 6099

Court: Hawaii Supreme Court; May 29, 1980; Hawaii; State Supreme Court

Narrative Opinion Summary

The case involves a civil lawsuit brought by Leonard, Alan, Beatrice, and Karen Feliciano against the City and County of Honolulu, alleging trespass, assault, battery, and malicious prosecution by police officers. The incident occurred during a family dispute at the Feliciano residence, leading to conflicting accounts between the plaintiffs and Officers Rodrigues and Sismar. The plaintiffs claimed excessive force and wrongful conduct by the officers, while the officers cited aggressive behavior by the Feliciano brothers, justifying their actions as self-defense. The trial court admitted character evidence regarding the Felicianos' violent reputation, applying an exception for assault and battery cases where self-defense is involved. The appellants challenged the verdict, particularly the admissibility of character evidence and the denial of a directed verdict for Alan Feliciano. The court held that character evidence was relevant due to the nature of the claims and that issues of credibility were appropriately left to the jury. Ultimately, the jury returned a verdict for the defendants, and the Supreme Court of Hawaii affirmed the lower court's rulings, including the denial of the directed verdict and the admissibility of character evidence, concluding that reasonable minds could differ on the facts presented.

Legal Issues Addressed

Admissibility of Character Evidence in Civil Actions

Application: The court allowed character evidence regarding the Felicianos' reputation for violence, applying an exception for assault and battery cases where self-defense is claimed.

Reasoning: Generally, character evidence is inadmissible in civil actions, but exceptions exist in cases of assault and battery, particularly when self-defense is claimed or when determining who initiated aggression.

Directed Verdict in Civil Cases

Application: The court denied a directed verdict for Alan Feliciano, emphasizing that issues of witness credibility and conflicting evidence are typically for the jury to decide.

Reasoning: The court asserted that when factual issues rely on witness credibility, it is typically for the jury to decide, even if the plaintiff's testimony is uncontradicted.

Role of Jury in Resolving Conflicting Testimonies

Application: The jury was tasked with resolving the conflicting accounts of the incident, which justified the court's decision to submit issues of fact to the jury.

Reasoning: Since multiple conflicting accounts of the events existed, the trial court correctly submitted the issue of Alan's credibility to the jury, leading to the conclusion that reasonable minds could differ on whether he suffered an assault.