discretionary function exception (Hawaii) · Go Syfert
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discretionary function exception in Hawaii

11 Hawaii opinions name it 2 courts 1969–2024 1 in the last five years

The cases below were cited by Hawaii courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Breed Ex Rel. Breed v. Shanergreen
haw · 1977 · cited in 5 Hawaii opinions naming this issue, 1982–2024
2 sentences

2024See Breed v. Shaner, 57 Haw. 656, 667 , 562 P.2d 436, 443 (1977) ("In this situation further facts must be 5 NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER adduced on the record to show that the decision to include a curve or other design feature involved the evaluation of broad policy factors before the court can decide that the discretionary function exception applies"); O'Grady, 140 Hawai‘i at 54, 398 P.3d at 643 .

2024See Breed v. Shaner, 57 Haw. 656, 667 , 562 P.2d 436, 443 (1977) ("In this situation further facts must be 5 NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER adduced on the record to show that the decision to include a curve or other design feature involved the evaluation of broad policy factors before the court can decide that the discretionary function exception applies"); O'Grady, 140 Hawai‘i at 54, 398 P.3d at 643 .

35
Tseu Ex Rel. Hobbs v. Jeytegreen
haw · 1998 · cited in 4 Hawaii opinions naming this issue, 1999–2017
2 sentences

2012Petitioner maintains that Jeyte decided there was a private right of action found by this court pursuant to the STLA "for a landlord damaged due to negligent investigation of a housing discrimination complaint by the Hawaii Civil Rights Commission (HCRC).” In deciding that the landlord defendants' counterclaim against the HCRC for negligent investigation should not be dismissed, this court said that "the investigation of a complaint [by the HCRC] does not entail a broad policy decision immune from suit under the discretionary function exception,” 88 Hawai'i at 89 , 962 P.2d at 348 , and "const

2012Petitioner maintains that Jeyte decided there was a private right of action found by this court pursuant to the STLA "for a landlord damaged due to negligent investigation of a housing discrimination complaint by the Hawaii Civil Rights Commission (HCRC).” In deciding that the landlord defendants' counterclaim against the HCRC for negligent investigation should not be dismissed, this court said that "the investigation of a complaint [by the HCRC] does not entail a broad policy decision immune from suit under the discretionary function exception,” 88 Hawai'i at 89 , 962 P.2d at 348 , and "const

24
Rogers v. Stategreen
haw · 1969 · cited in 4 Hawaii opinions naming this issue, 1970–2017
2 sentences

2017See Taylor-Rice, 91 Hawai'i at 78 , 979 P.2d at 1104 (discussing the analysis in Breed); see also Rogers, 51 Haw. at 297 , 459 P.2d at 381 (noting a federal decision that determined that “the decision to construct a post office building involved discretion but the omission to install handrails was an operational level act”); Julius Rothschild & Co. v. State, 66 Haw. 76, 80 , 655 P.2d 877, 881 (1982) (holding that the discretionary function exception applies to the State’s decision of whether to replace or reconstruct a bridge since “[i]t would require a weighing of priorities at the higher lev

2017See Taylor-Rice, 91 Hawai'i at 78 , 979 P.2d at 1104 (discussing the analysis in Breed); see also Rogers, 51 Haw. at 297 , 459 P.2d at 381 (noting a federal decision that determined that “the decision to construct a post office building involved discretion but the omission to install handrails was an operational level act”); Julius Rothschild & Co. v. State, 66 Haw. 76, 80 , 655 P.2d 877, 881 (1982) (holding that the discretionary function exception applies to the State’s decision of whether to replace or reconstruct a bridge since “[i]t would require a weighing of priorities at the higher lev

14
Julius Rothschild & Co. v. Stategreen
haw · 1982 · cited in 2 Hawaii opinions naming this issue, 1998–2017
2 sentences

2017See Taylor-Rice, 91 Hawai'i at 78 , 979 P.2d at 1104 (discussing the analysis in Breed); see also Rogers, 51 Haw. at 297 , 459 P.2d at 381 (noting a federal decision that determined that “the decision to construct a post office building involved discretion but the omission to install handrails was an operational level act”); Julius Rothschild & Co. v. State, 66 Haw. 76, 80 , 655 P.2d 877, 881 (1982) (holding that the discretionary function exception applies to the State’s decision of whether to replace or reconstruct a bridge since “[i]t would require a weighing of priorities at the higher lev

2017See Taylor-Rice, 91 Hawai'i at 78 , 979 P.2d at 1104 (discussing the analysis in Breed); see also Rogers, 51 Haw. at 297 , 459 P.2d at 381 (noting a federal decision that determined that “the decision to construct a post office building involved discretion but the omission to install handrails was an operational level act”); Julius Rothschild & Co. v. State, 66 Haw. 76, 80 , 655 P.2d 877, 881 (1982) (holding that the discretionary function exception applies to the State’s decision of whether to replace or reconstruct a bridge since “[i]t would require a weighing of priorities at the higher lev

12
O'Grady v. State.green
haw · 2017 · cited in 1 Hawaii opinions naming this issue, 2024–2024
2 sentences

2024Regarding the Discretionary Function Exception of HRS § 662-15, "the State bears the burden to assert and prove the application of the discretionary function exception," and its scope must be determined "on a case-by-case basis." O'Grady v. State, 140 Hawai‘i 36, 53-55, 398 P.3d 625, 642-44 (2017).

2024See Breed v. Shaner, 57 Haw. 656, 667 , 562 P.2d 436, 443 (1977) ("In this situation further facts must be 5 NOT FOR PUBLICATION IN WEST'S HAWAIʻI REPORTS AND PACIFIC REPORTER adduced on the record to show that the decision to include a curve or other design feature involved the evaluation of broad policy factors before the court can decide that the discretionary function exception applies"); O'Grady, 140 Hawai‘i at 54, 398 P.3d at 643 .

11
Mr. & Mrs. Doe Parents No. 1 v. State, Department of Educationgreen
haw · 2002 · cited in 1 Hawaii opinions naming this issue, 2017–2017
2 sentences

2017See, e.g„ Doe Parents No. 1 v. Dep’t of Educ., 100 Hawai'i 34, 68 , 58 P.3d 545, 579 (2002).

2017See, e.g„ Doe Parents No. 1 v. Dep’t of Educ., 100 Hawai'i 34, 68 , 58 P.3d 545, 579 (2002).

11
Stewart v. United Statesgreen
ca7 · 1952 · cited in 1 Hawaii opinions naming this issue, 2017–2017
2 sentences

2017Zimring, 52 Haw. at 478 , 479 P.2d at 206 (citing Stewart v. United States, 199 F.2d 517, 620 (7th Cir. 1962)) 20 (concluding that any exceptions from the State’s waiver of sovereign immunity “is a matter of defense”); see also 61A Am.

2017The exceptions provided for in HRS § 662-15 define the scope of the application of the State Tort Liability Act and, consequently, the scope of tort claims that may be brought against the State. 20 , Stewart held that if the government desires to rely on the discretionary function exception, it has a right to do so in defense of the action, "providing such defense is aptly pleaded and proven." 199 F.2d at 520 . 21 .

11
Parrott v. United Statesgreen
ca7 · 2008 · cited in 1 Hawaii opinions naming this issue, 2017–2017
1 sentence

2017Thus, the State bears the burden to assert and prove the application of the discretionary function exception to liability under the State Tort Liability Act, See Parrott v. United States, 536 F.3d 629, 634-35 (7th Cir. 2008) (concluding that the discretionary function exception operates as an affirmative defense to the Federal Tort Claim Act). 21 The issue that is presented in this case is whether the State is liable for its failure to have a routine, coordinated system of rockfall mitigation at the operational level.

11
Taylor-Rice v. Stategreen
haw · 1999 · cited in 1 Hawaii opinions naming this issue, 2017–2017
2 sentences

2017See Taylor-Rice v. State, 91 Hawai'i 60, 77 , 979 P.2d 1086, 1103 (1999) (discussing the discretionary function exception separately from the elements of negligence).

2017See Taylor-Rice v. State, 91 Hawai'i 60, 77 , 979 P.2d 1086, 1103 (1999) (discussing the discretionary function exception separately from the elements of negligence).

11
Giovanna Carboniero Cestonaro, Individually and as Personal Representative of the Estate of Danielle Cestonaro v. United Statesgreen
ca3 · 2000 · cited in 1 Hawaii opinions naming this issue, 2017–2017
2 sentences

2017Many other jurisdictions consider similar exceptions to be affirmative defenses, although there is some disagreement. 14 Charles Alan Wright et al., Federal Practice and Procedure: Jurisdiction and Related Matters 3d § 3658 (4th ed. 2015) (“The plaintiff bears tire initial burden of alleging subject matter jurisdiction under the FTCA, but generally it is held that the Government bears the burden of proving the applicability of the discretionary function exception, although there is disagreement."); see also Keller v. United States, 771 F.3d 1021, 1023 (7th Cir. 2014) (“The discretionary functi

2017Many other jurisdictions consider similar exceptions to be affirmative defenses, although there is some disagreement. 14 Charles Alan Wright et al., Federal Practice and Procedure: Jurisdiction and Related Matters 3d § 3658 (4th ed. 2015) (“The plaintiff bears tire initial burden of alleging subject matter jurisdiction under the FTCA, but generally it is held that the Government bears the burden of proving the applicability of the discretionary function exception, although there is disagreement."); see also Keller v. United States, 771 F.3d 1021, 1023 (7th Cir. 2014) (“The discretionary functi

11
Anderson v. Stategreen
iowa · 2005 · cited in 1 Hawaii opinions naming this issue, 2017–2017
2 sentences

2017Many other jurisdictions consider similar exceptions to be affirmative defenses, although there is some disagreement. 14 Charles Alan Wright et al., Federal Practice and Procedure: Jurisdiction and Related Matters 3d § 3658 (4th ed. 2015) (“The plaintiff bears tire initial burden of alleging subject matter jurisdiction under the FTCA, but generally it is held that the Government bears the burden of proving the applicability of the discretionary function exception, although there is disagreement."); see also Keller v. United States, 771 F.3d 1021, 1023 (7th Cir. 2014) (“The discretionary functi

2017Many other jurisdictions consider similar exceptions to be affirmative defenses, although there is some disagreement. 14 Charles Alan Wright et al., Federal Practice and Procedure: Jurisdiction and Related Matters 3d § 3658 (4th ed. 2015) (“The plaintiff bears tire initial burden of alleging subject matter jurisdiction under the FTCA, but generally it is held that the Government bears the burden of proving the applicability of the discretionary function exception, although there is disagreement."); see also Keller v. United States, 771 F.3d 1021, 1023 (7th Cir. 2014) (“The discretionary functi

11
Keller v. United Statesgreen
ca7 · 2014 · cited in 1 Hawaii opinions naming this issue, 2017–2017
2 sentences

2017Many other jurisdictions consider similar exceptions to be affirmative defenses, although there is some disagreement. 14 Charles Alan Wright et al., Federal Practice and Procedure: Jurisdiction and Related Matters 3d § 3658 (4th ed. 2015) (“The plaintiff bears tire initial burden of alleging subject matter jurisdiction under the FTCA, but generally it is held that the Government bears the burden of proving the applicability of the discretionary function exception, although there is disagreement."); see also Keller v. United States, 771 F.3d 1021, 1023 (7th Cir. 2014) (“The discretionary functi

2017Many other jurisdictions consider similar exceptions to be affirmative defenses, although there is some disagreement. 14 Charles Alan Wright et al., Federal Practice and Procedure: Jurisdiction and Related Matters 3d § 3658 (4th ed. 2015) (“The plaintiff bears tire initial burden of alleging subject matter jurisdiction under the FTCA, but generally it is held that the Government bears the burden of proving the applicability of the discretionary function exception, although there is disagreement."); see also Keller v. United States, 771 F.3d 1021, 1023 (7th Cir. 2014) (“The discretionary functi

11
Ross v. Schackelgreen
utah · 1996 · cited in 1 Hawaii opinions naming this issue, 2013–2013
1 sentence

2013Id. at 1172 (Stewart, C.J., dissenting).

11
Taylor-Rice v. Stategreen
haw · 2004 · cited in 1 Hawaii opinions naming this issue, 2007–2007
2 sentences

2007We disagree. “[I]t is well established that the State’s liability is limited by its sovereign immunity, except where there has been a ‘clear relinquishment’ of immunity and the State has consented to be sued.” Taylor-Rice v. State, 105 Hawai'i 104, 109-10 , 94 P.3d 659, 664-65 (2004) (citation omitted).

2007We disagree. "[I]t is well established that the State's liability is limited by its sovereign immunity, except where there has been a `clear relinquishment' of immunity and the State has consented to be sued." Taylor-Rice v. State, 105 Hawai`i 104, 109-10, 94 P.3d 659, 664-65 (2004) (citation omitted).

11
Crenshaw v. United Statesgreen
txsd · 1997 · cited in 1 Hawaii opinions naming this issue, 1998–1998
1 sentence

1998See Crenshaw v. United States, 959 F.Supp. 399 (S.D.Tex.1997).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Hawaii. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
State Ex Rel. Kobayashi v. Zimring green
haw · 1970
2 sentences

2017Zimring, 52 Haw. at 478 , 479 P.2d at 206 (citing Stewart v. United States, 199 F.2d 517, 620 (7th Cir. 1962)) 20 (concluding that any exceptions from the State’s waiver of sovereign immunity “is a matter of defense”); see also 61A Am.

2017Zimring, 52 Haw. at 478 , 479 P.2d at 206 (citing Stewart v. United States, 199 F.2d 517, 620 (7th Cir. 1962)) 20 (concluding that any exceptions from the State’s waiver of sovereign immunity “is a matter of defense”); see also 61A Am.

12017–2017
cluster 741892 green
ca9 · 1997
2 sentences

2017Many other jurisdictions consider similar exceptions to be affirmative defenses, although there is some disagreement. 14 Charles Alan Wright et al., Federal Practice and Procedure: Jurisdiction and Related Matters 3d § 3658 (4th ed. 2015) (“The plaintiff bears tire initial burden of alleging subject matter jurisdiction under the FTCA, but generally it is held that the Government bears the burden of proving the applicability of the discretionary function exception, although there is disagreement."); see also Keller v. United States, 771 F.3d 1021, 1023 (7th Cir. 2014) (“The discretionary functi

2017Many other jurisdictions consider similar exceptions to be affirmative defenses, although there is some disagreement. 14 Charles Alan Wright et al., Federal Practice and Procedure: Jurisdiction and Related Matters 3d § 3658 (4th ed. 2015) (“The plaintiff bears tire initial burden of alleging subject matter jurisdiction under the FTCA, but generally it is held that the Government bears the burden of proving the applicability of the discretionary function exception, although there is disagreement."); see also Keller v. United States, 771 F.3d 1021, 1023 (7th Cir. 2014) (“The discretionary functi

12017–2017
Rodrigues v. State green
haw · 1970
2 sentences

1998Adoption of the Gaubert standard would run directly contrary to our past holdings that the discretionary function exception did not apply to the act of designing a highway, Breed v. Shaner, supra, the placement of road signs and strip-ings, Rogers v. State, 51 Haw. 293 , 459 P.2d 378 (1969), or the maintenance of drainage culverts, Rodrigues v. State, 52 Haw. 156 , 472 P.2d 509 (1970).

1998Adoption of the Gaubert standard would run directly contrary to our past holdings that the discretionary function exception did not apply to the act of designing a highway, Breed v. Shaner, supra, the placement of road signs and strip-ings, Rogers v. State, 51 Haw. 293 , 459 P.2d 378 (1969), or the maintenance of drainage culverts, Rodrigues v. State, 52 Haw. 156 , 472 P.2d 509 (1970).

11998–1998
United States v. Gaubert green
scotus · 1991
2 sentences

1998Both the HCRC and the State of Hawaii, as amicus curiae, cite to the United States Supreme Court’s decision in United States v. Gaubert, 499 U.S. 315 , 111 S.Ct. 1267 , 113 L.Ed.2d 335 (1991), in support of the argument that the HCRC’s investigation entails a discretionary function.

1998Both the HCRC and the State of Hawaii, as amicus curiae, cite to the United States Supreme Court’s decision in United States v. Gaubert, 499 U.S. 315 , 111 S.Ct. 1267 , 113 L.Ed.2d 335 (1991), in support of the argument that the HCRC’s investigation entails a discretionary function.

11998–1998
Leopold W. Mahler and Helen E. Mahler, His Wife, and Bertha Ebertsheim v. United States green
ca3 · 1962
1 sentence

1977The United States Court of Appeals for the Ninth Circuit expressed this proposition in United States v. Hunsucker, supra note 7, at 103: Where discretion ends and actionable negligence begins for the purpose of this exception cannot be defined without reference to the factual situations in which the question of applicability of the exception has arisen. *668 The State has cited Mahler v. United States, 306 F.2d 713 (3rd Cir. 1962), cert. denied 371 U.S. 293 (1962), in support of its contention that highway design is a discretionary function as a matter of law.

11977–1977
Sisley v. United States green
akd · 1962
1 sentence

1970The State's sole reliance on Sisley and Shank v. United States, 202 F. Supp. 273 (D.Alaska 1962) for the proposition that maintenance of a culvert is within the scope of the discretionary function exception is misplaced.

11970–1970
The American Exchange Bank of Madison, Wisconsin, as of the Estate of Pauline H. Williams, Deceased v. United States green
ca7 · 1958
1 sentence

1969Indian Towing Co. v. United States, supra; American Exchange Bank of Madison v. United States, 257 F.2d 938 (1958); United States v. Hunsucker, 314 F.2d 98 (9th Cir. 1962).

11969–1969
United States v. Thomas O. Hunsucker and Eva Newman Hunsucker green
ca9 · 1962
1 sentence

1969Indian Towing Co. v. United States, supra; American Exchange Bank of Madison v. United States, 257 F.2d 938 (1958); United States v. Hunsucker, 314 F.2d 98 (9th Cir. 1962).

11969–1969

Statutes the citing opinions construe

HI § Haw. Rev. Stat. § 662-15 (10) HI § Haw. Rev. Stat. § 662-2 (8)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

KS 69 (1982–2024) MA 65 (1983–2025) TX 46 (1993–2024) MN 44 (1974–2025) IA 37 (1977–2025) TN 36 (1990–2024) LA 31 (1990–2017) VT 29 (1993–2026) MS 29 (1997–2026) NE 28 (1984–2021) UT 28 (1980–2026) AK 23 (1972–2012) AL 23 (1988–2017) ID 20 (1981–2022) IN 19 (1988–2020) GA 19 (1995–2024) FL 18 (1979–2009) ME 17 (1987–2022) NH 17 (1983–2025) ND 13 (1974–2022) NV 11 (1987–2020) HI 11 (1969–2024) OR 10 (1978–2016) NJ 7 (1983–2004) SD 7 (1990–2003) DC 7 (1979–2009) CA 6 (1968–2023) OH 5 (1987–2016) MO 3 (1993–2018) MT 3 (1990–1994) NY 3 (1973–2024) WA 3 (1978–1991) MD 2 (2011–2025) OK 2 (1990–1999) WY 2 (1980–1989) DE 2 (1984–1992)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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