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Outdoor Circle v. Harold KL Castle Trust Estate

Citations: 677 P.2d 965; 67 Haw. 1Docket: 8554, 9025

Court: Hawaii Supreme Court; January 8, 1984; Hawaii; State Supreme Court

Narrative Opinion Summary

The Supreme Court of Hawaii addressed a petition for a writ of certiorari regarding a decision from the Intermediate Court of Appeals, which had upheld a circuit court's affirmation of a ruling by the Land Use Commission in a contested case involving multiple appellants, including various community and environmental organizations, and the Department of Planning and Economic Development. The Supreme Court concurred with the Intermediate Court's conclusion and reasoning, denying the petition. Notably, the Intermediate Court adopted a "right/wrong" standard for reviewing the circuit court's decisions on administrative agency determinations, explicitly rejecting the "clearly erroneous" standard. The Supreme Court concluded that, since the circuit court's affirmation of the Land Use Commission's actions was justifiable under both standards, it did not need to decide on the appropriate standard of review for such appeals.

Legal Issues Addressed

Affirmation of Administrative Decisions

Application: The Supreme Court affirmed the Intermediate Court's decision and reasoning, indicating that the circuit court's affirmation of the Land Use Commission's actions was justifiable under both the 'right/wrong' and 'clearly erroneous' standards.

Reasoning: The Supreme Court concluded that, since the circuit court's affirmation of the Land Use Commission's actions was justifiable under both standards, it did not need to decide on the appropriate standard of review for such appeals.

Standard of Review for Administrative Agency Determinations

Application: The Intermediate Court adopted a 'right/wrong' standard for reviewing the circuit court's decisions on administrative agency determinations, rejecting the 'clearly erroneous' standard.

Reasoning: Notably, the Intermediate Court adopted a 'right/wrong' standard for reviewing the circuit court's decisions on administrative agency determinations, explicitly rejecting the 'clearly erroneous' standard.