Graham v. Collins

Summary

The Supreme Court of the State of Hawaiʻi denied a petition for a writ of mandamus challenging an order disqualifying counsel in a district court proceeding. The court held that the former representation was substantially related to the litigation and that the former and present clients’ interests were materially adverse, and it found no flagrant and manifest abuse of discretion.

Holdings

1. The district court's order granting the motion to disqualify counsel did not amount to a flagrant and manifest abuse of discretion; therefore, mandamus relief was denied.

Questions Presented

1. Whether the district court's order disqualifying counsel constituted a flagrant and manifest abuse of discretion warranting a writ of mandamus.
2. Whether counsel's former representation was substantially related to the current litigation and whether the former and present clients' interests were materially adverse under Hawaiʻi Rules of Professional Conduct Rule 1.9(a).

Disposition

writ_denied