causation requirement (Hawaii) · Go Syfert
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causation requirement in Hawaii

9 Hawaii opinions name it 2 courts 1995–2018 0 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 (8)

CaseFollowedCited
Davis v. Four Seasons Hotel Ltd.green
haw · 2010 · cited in 4 Hawaii opinions naming this issue, 2010–2018
2 sentences

2018Cf. Davis , 122 Hawai'i at 439 , 228 P.3d at 319 (explaining in the context of a claim for unfair method of competition (UMOC) that "although the deeming language of HRS § 481B-4 eliminates the requirement that a plaintiff prove that a defendant's conduct that violates chapter 481B (including HRS § 481B-14 ) constitutes an unfair method of competition, it does not purport to modify the causation requirement of HRS § 480-13."); Gurrobat , 133 Hawai'i at 23 , 323 P.3d at 814 (interpreting the causation element for a UMOC claim based on a violation of HRS § 481B-4, and stating that "a plaintiff n

2018Cf. Davis , 122 Hawai'i at 439 , 228 P.3d at 319 (explaining in the context of a claim for unfair method of competition (UMOC) that "although the deeming language of HRS § 481B-4 eliminates the requirement that a plaintiff prove that a defendant's conduct that violates chapter 481B (including HRS § 481B-14 ) constitutes an unfair method of competition, it does not purport to modify the causation requirement of HRS § 480-13."); Gurrobat , 133 Hawai'i at 23 , 323 P.3d at 814 (interpreting the causation element for a UMOC claim based on a violation of HRS § 481B-4, and stating that "a plaintiff n

24
Hawaii Medical Ass'n v. Hawaii Medical Service Ass'ngreen
haw · 2006 · cited in 2 Hawaii opinions naming this issue, 2010–2013
2 sentences

2013However, those footnotes merely note that "federal case law has interpreted the 'injury to business or property’ language of section 4 as a causation requirement, requiring a showing of 'antitrust injury.' ’Plaintiffs must prove an injury of the type the antitrust laws were intended to prevent....’” Robert's Hawai'i, 91 Hawai'i at 254 n. 31, 982 P.2d at 863 n. 31 (quoting Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc., 429 U.S. 477, 489 , 97 S.Ct. 690 , 50 L.Ed.2d 701 (1977)); accord HMA, 113 Hawai'i at 114 n. 30, 148 P.3d at 1216 n. 30.

2013However, those footnotes merely note that "federal case law has interpreted the 'injury to business or property’ language of section 4 as a causation requirement, requiring a showing of 'antitrust injury.' ’Plaintiffs must prove an injury of the type the antitrust laws were intended to prevent....’” Robert's Hawai'i, 91 Hawai'i at 254 n. 31, 982 P.2d at 863 n. 31 (quoting Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc., 429 U.S. 477, 489 , 97 S.Ct. 690 , 50 L.Ed.2d 701 (1977)); accord HMA, 113 Hawai'i at 114 n. 30, 148 P.3d at 1216 n. 30.

12
Gurrobat v. HTH Corporation.green
haw · 2014 · cited in 1 Hawaii opinions naming this issue, 2018–2018
2 sentences

2018Cf. Davis , 122 Hawai'i at 439 , 228 P.3d at 319 (explaining in the context of a claim for unfair method of competition (UMOC) that "although the deeming language of HRS § 481B-4 eliminates the requirement that a plaintiff prove that a defendant's conduct that violates chapter 481B (including HRS § 481B-14 ) constitutes an unfair method of competition, it does not purport to modify the causation requirement of HRS § 480-13."); Gurrobat , 133 Hawai'i at 23 , 323 P.3d at 814 (interpreting the causation element for a UMOC claim based on a violation of HRS § 481B-4, and stating that "a plaintiff n

2018Cf. Davis , 122 Hawai'i at 439 , 228 P.3d at 319 (explaining in the context of a claim for unfair method of competition (UMOC) that "although the deeming language of HRS § 481B-4 eliminates the requirement that a plaintiff prove that a defendant's conduct that violates chapter 481B (including HRS § 481B-14 ) constitutes an unfair method of competition, it does not purport to modify the causation requirement of HRS § 480-13."); Gurrobat , 133 Hawai'i at 23 , 323 P.3d at 814 (interpreting the causation element for a UMOC claim based on a violation of HRS § 481B-4, and stating that "a plaintiff n

11
Knodle v. Waikiki Gateway Hotel, Inc.green
haw · 1987 · cited in 1 Hawaii opinions naming this issue, 2017–2017
2 sentences

2017See id. at 389 , 742 P.2d at 386 .

2017See id. at 389 , 742 P.2d at 386 .

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

2017See generally Taylor-Rice, 91 Hawai'i at 70 , 979 P.2d at 1096 (defining the State’s duty with respect to designing, constructing, and maintaining public highways).

2017See generally Taylor-Rice, 91 Hawai'i at 70 , 979 P.2d at 1096 (defining the State’s duty with respect to designing, constructing, and maintaining public highways).

11
Transport Insurance Co. v. Fordgreen
kyctapp · 1994 · cited in 1 Hawaii opinions naming this issue, 2008–2008
2 sentences

2008In applying the causation requirement of the test, the court noted that “[t]he causal relationship between the injury and the use of the insured vehicle was [the driver’s] towing of the vehicle and his need to be in and about it to perform his duties.” Id. at 903 .

2008In applying the causation requirement of the test, the court noted that "[t]he causal relationship between the injury and the use of the insured vehicle was [the driver's] towing of the vehicle and his need to be in and about it to perform his duties." Id. at 903.

11
Robert W. Hall v. Gale A. Norton, Secretary of the Interior United States Department of the Interiorgreen
ca9 · 2001 · cited in 1 Hawaii opinions naming this issue, 2007–2007
1 sentence

2007In Hall v. Norton, the Ninth Circuit stated that the causation requirement is satisfied if the plaintiff establishes a "reasonable probability" of a threat to the plaintiffs concrete interests. 266 F.3d 969, 976 (9th Cir.2001).

11
Fain v. Smithgreen
ala · 1985 · cited in 1 Hawaii opinions naming this issue, 1995–1995
1 sentence

1995Id. at 1155 (quotation marks and citation omitted). 5 Therefore, the primary practical difference between the objective standard and the modified objective standard is the method by which the characteristics of the actual patient are considered in the causation analysis.

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 (4)

CaseCitedYears
Robert's Hawaii School Bus, Inc. v. Laupahoehoe Transportation Co. red
haw · 1999
2 sentences

2013However, those footnotes merely note that "federal case law has interpreted the 'injury to business or property’ language of section 4 as a causation requirement, requiring a showing of 'antitrust injury.' ’Plaintiffs must prove an injury of the type the antitrust laws were intended to prevent....’” Robert's Hawai'i, 91 Hawai'i at 254 n. 31, 982 P.2d at 863 n. 31 (quoting Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc., 429 U.S. 477, 489 , 97 S.Ct. 690 , 50 L.Ed.2d 701 (1977)); accord HMA, 113 Hawai'i at 114 n. 30, 148 P.3d at 1216 n. 30.

2013However, those footnotes merely note that "federal case law has interpreted the 'injury to business or property’ language of section 4 as a causation requirement, requiring a showing of 'antitrust injury.' ’Plaintiffs must prove an injury of the type the antitrust laws were intended to prevent....’” Robert's Hawai'i, 91 Hawai'i at 254 n. 31, 982 P.2d at 863 n. 31 (quoting Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc., 429 U.S. 477, 489 , 97 S.Ct. 690 , 50 L.Ed.2d 701 (1977)); accord HMA, 113 Hawai'i at 114 n. 30, 148 P.3d at 1216 n. 30.

42006–2014
Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc. green
scotus · 1977
2 sentences

2013However, those footnotes merely note that "federal case law has interpreted the 'injury to business or property’ language of section 4 as a causation requirement, requiring a showing of 'antitrust injury.' ’Plaintiffs must prove an injury of the type the antitrust laws were intended to prevent....’” Robert's Hawai'i, 91 Hawai'i at 254 n. 31, 982 P.2d at 863 n. 31 (quoting Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc., 429 U.S. 477, 489 , 97 S.Ct. 690 , 50 L.Ed.2d 701 (1977)); accord HMA, 113 Hawai'i at 114 n. 30, 148 P.3d at 1216 n. 30.

2013However, those footnotes merely note that "federal case law has interpreted the 'injury to business or property’ language of section 4 as a causation requirement, requiring a showing of 'antitrust injury.' ’Plaintiffs must prove an injury of the type the antitrust laws were intended to prevent....’” Robert's Hawai'i, 91 Hawai'i at 254 n. 31, 982 P.2d at 863 n. 31 (quoting Brunswick Corp. v. Pueblo Bowl-O-Mat, Inc., 429 U.S. 477, 489 , 97 S.Ct. 690 , 50 L.Ed.2d 701 (1977)); accord HMA, 113 Hawai'i at 114 n. 30, 148 P.3d at 1216 n. 30.

22010–2013
Dawes v. First Insurance Co. of Hawai'i green
haw · 1994
2 sentences

2008Id. at 127 n. 10, 883 P.2d at 48 n. 10 (coverage is a function of victim's connection with the insured vehicle, and not the victim's use of the vehicle).

2008Id. at 127 n. 10, 883 P.2d at 48 n. 10 (coverage is a function of victim's connection with the insured vehicle, and not the victim's use of the vehicle).

12008–2008
Ai v. Frank Huff Agency, Ltd. green
haw · 1980
1 sentence

2006We note that the Ai court set forth a fourth element—"a showing that the action is in the public interest or that the defendant is a merchant.” Id. at 617, 607 P.2d at 1311 .

12006–2006

Statutes the citing opinions construe

HI § Haw. Rev. Stat. § 480-13 (5) HI § Haw. Rev. Stat. § 480-2 (5) HI § Haw. Rev. Stat. § 388-6 (3) HI § Haw. Rev. Stat. § 480-1 (3)

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

TX 252 (1978–2026) CA 161 (1978–2026) PA 61 (1952–2026) IL 49 (1980–2025) IA 48 (1982–2023) MI 47 (1988–2026) MO 40 (1989–2024) OH 33 (1991–2023) UT 30 (1986–2026) MA 28 (1980–2025) OR 28 (1990–2024) NY 27 (1933–2024) MD 26 (1977–2022) AL 26 (1981–2025) MN 25 (1987–2026) LA 24 (1984–2019) NM 23 (1938–2024) CT 22 (1991–2025) WA 22 (1983–2023) FL 21 (1984–2025) NJ 19 (1990–2026) WI 19 (1995–2024) GA 18 (1902–2025) SD 16 (1992–2020) VA 13 (1988–2024) CO 13 (1984–2020) AZ 13 (1997–2024) AK 12 (1988–2022) DC 12 (1990–2024) ID 12 (2005–2026) MT 11 (1990–2022) IN 11 (1986–2026) TN 11 (1997–2019) VT 10 (1991–2024) NC 10 (1988–2020) HI 9 (1995–2018) KS 9 (1991–2025) ME 8 (1982–2021) WY 8 (1982–2013) NE 8 (1996–2026) RI 7 (1993–2008) NH 7 (1986–2021) MS 7 (1992–2011) AR 6 (1999–2025) DE 4 (2014–2024) KY 3 (2006–2026) WV 2 (1997–2001) NV 2 (2012–2026) OK 2 (1981–2016) ND 2 (1994–2010)

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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