Summary
This appellate court order affirms the circuit court's final judgment granting the judicial dissolution of Pumehana Hui LP following a dispute among its partners. The appellant challenged several lower court rulings, including the denial of a discovery continuance, the grant of summary judgment based on partner deadlock and ill-will, and the denial of a motion for relief from judgment under HRCP Rule 60(b)(4). The Intermediate Court of Appeals found no legal error or abuse of discretion regarding procedural due process, joinder of parties, judicial recusal, or the issuance of an injunction against direct contact between opposing counsel's clients.
Topics
Practice areas
Questions Presented
- Whether the circuit court erred in treating the dissolution application as a special proceeding outside the Hawai‘i Rules of Civil Procedure.
- Whether the partnership itself must be joined as a party to its own judicial dissolution proceeding.
- Whether the circuit court abused its discretion by denying a continuance of discovery under HRCP Rule 56(f).
- Whether the circuit court properly granted summary judgment to MJF.
- Whether the circuit court properly denied Greene Lane's motion for reconsideration.
- Whether Judge Cataldo should have recused herself for alleged conflict of interest.
- Whether only district courts have authority to issue a temporary restraining order under HRS § 604‑10.5(b).
- Whether the circuit court properly denied Greene Lane's HRCP Rule 60(b)(4) motion.
Holdings
- The circuit court did not err; the application is a civil action subject to the HRCP.
- The partnership need not be joined as a party; the ULPA and RULPA do not require it.
- The denial was not an abuse of discretion; the court properly exercised its discretion under Rule 56(f).
- The summary judgment was proper; no genuine issue of material fact existed.
- Denial was proper; the alleged new evidence was not truly new or material.
- Recusal was not required; prior involvement in unrelated malpractice cases does not create a disqualifying conflict.
- Circuit courts have inherent power to issue injunctions; the statute does not strip that authority.
- Denial was proper; the judgment was not void and due process was not violated.
Factual background
In February 2013 MJF Development Corp., Greene Lane Capital LLC, Dennis W. Mahoney (as trustee) and Renee E. Mola formed the limited partnership Pumehana Hui LP to develop 180 affordable condominium units. MJF filed an amended application for judicial dissolution in March 2020, moved for summary judgment, and the circuit court entered a final judgment in April 2021 favoring MJF.
Procedural history
The circuit court entered a final judgment in favor of MJF Development Corp. and against Greene Lane Capital LLC, granted MJF's summary judgment motion, denied Greene Lane's motions to dismiss, to reconsider, and its HRCP Rule 60(b)(4) motion, and issued various injunction and discovery orders.