Keahole Defense Coalition, Inc. v. Board of Land & Natural Resources, 110 Haw. 419

Summary

The Supreme Court of Hawaiʻi held that Waimana Enterprises, Inc. lacked standing to challenge the vacatur of a judgment concerning the Board of Land and Natural Resources' extension of Hawaii Electric Light Company's construction deadline for the Keahole power station. The court concluded that Waimana was collaterally estopped from relitigating standing and lacked a sufficient property interest to establish a due process violation. It affirmed the circuit court's first amended final judgment vacating the prior judgment reversing the agency's decision.

Holdings

1. Waimana lacked standing to oppose the Rule 60(b) motion or appeal the first amended final judgment because it lacked standing to oppose the underlying agency decision and therefore could not satisfy the second requirement for standing to appeal.
2. Collateral estoppel barred Waimana from relitigating whether it had standing to challenge decisions concerning CDUA/CDUP HA-487A.
3. Waimana failed to establish a constitutionally protected property interest in its economic interests or exclusive telecommunications license sufficient to support a due process claim or standing.
4. The circuit court had authority to determine Waimana's standing while considering the Rule 60(b) motion because standing is jurisdictional and may be addressed at any stage of a case.
5. The circuit court did not abuse its discretion by vacating its prior order and final judgment because settlement rendered the agency appeal moot and the equities and public interest supported vacatur.

Questions Presented

1. Whether Waimana had standing to oppose the motion to vacate the circuit court's prior judgment and to appeal the resulting judgment.
2. Whether collateral estoppel barred Waimana from relitigating its standing to challenge decisions concerning CDUA/CDUP HA-487A.
3. Whether Waimana possessed a constitutionally protected property interest sufficient to support a due process claim and standing.
4. Whether the circuit court had authority to determine Waimana's standing while considering the Rule 60(b) motion after remand.
5. Whether the circuit court abused its discretion by vacating its prior judgment because settlement rendered the appeal moot and vacatur served the public interest.
6. Whether the vacatur violated due process or equal protection or breached the State's public-trust obligations.

Disposition

affirmed