professional standard (Hawaii) · Go Syfert
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professional standard in Hawaii

9 Hawaii opinions name it 2 courts 1968–2020 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 (5)

CaseFollowedCited
Matsuura v. EI Du Pont De Nemours and Co.green
haw · 2003 · cited in 1 Hawaii opinions naming this issue, 2020–2020
1 sentence

2020“The scope of any privilege is based upon policy considerations.” Matsuura v. E.I. du Pont de Nemours & Co., 102 Hawaiʻi 149, 155, 73 P.3d 687, 693 (2003).

11
Delmonte v. State Farm Fire & Casualty Co.green
haw · 1999 · cited in 1 Hawaii opinions naming this issue, 2014–2014
2 sentences

2014In such circumstance, the insurer may be liable “if its actions caused the attorney’s breach of [his or her] duties.” Id. (emphasis added); see also Delmonte, 90 Hawai'i at 54 , 975 P.2d at 1174 (explaining that if the retained attorney breached his ethical duties to his clients, the insureds, and such breach was “causally induced” by the insurer’s action, then the insurer may be liable for bad faith (emphasis added)).

2014In such circumstance, the insurer may be liable “if its actions caused the attorney’s breach of [his or her] duties.” Id. (emphasis added); see also Delmonte, 90 Hawai'i at 54 , 975 P.2d at 1174 (explaining that if the retained attorney breached his ethical duties to his clients, the insureds, and such breach was “causally induced” by the insurer’s action, then the insurer may be liable for bad faith (emphasis added)).

11
In the Interest of Doegreen
haw · 1994 · cited in 1 Hawaii opinions naming this issue, 2001–2001
2 sentences

2001The circuit court farther erred in refusing to instmct the jury that, in the context of a terroristic threatening prosecution, the attributes of the defendant and the complainant may be taken into consideration in assessing whether, under the circumstances, the defendant’s remark was a “tme threat. ” Valdivia further contends that the circuit court erred in refusing, over his objection, to *479 instruct the jury that, “[w]here a threat is directed at a police officer, you may consider that police officers are trained to a professional standard of behavior that ordinary citizens might not be ex

2001The circuit court farther erred in refusing to instmct the jury that, in the context of a terroristic threatening prosecution, the attributes of the defendant and the complainant may be taken into consideration in assessing whether, under the circumstances, the defendant’s remark was a “tme threat. ” Valdivia further contends that the circuit court erred in refusing, over his objection, to *479 instruct the jury that, “[w]here a threat is directed at a police officer, you may consider that police officers are trained to a professional standard of behavior that ordinary citizens might not be ex

11
Allen v. Lefkoff, Duncan, Grimes & Dermer, P.C.green
ga · 1995 · cited in 1 Hawaii opinions naming this issue, 1999–1999
2 sentences

1999"Given the potential consequences of their violation and the fundamental nature of their purpose, it would not be logical or reasonable to say that the Bar Rules, in general, do not play a role in shaping the 'care and skill’ ordinarily exercised by attorneys practicing law[.]” Allen v. Lefkoff, Duncan, Grimes & Dermer, P.C., 265 Ga. 374 , 453 S.E.2d 719, 721 (1995).

1999"Given the potential consequences of their violation and the fundamental nature of their purpose, it would not be logical or reasonable to say that the Bar Rules, in general, do not play a role in shaping the 'care and skill’ ordinarily exercised by attorneys practicing law[.]” Allen v. Lefkoff, Duncan, Grimes & Dermer, P.C., 265 Ga. 374 , 453 S.E.2d 719, 721 (1995).

11
Best Place, Inc. v. Penn America Insurance Co.green
haw · 1996 · cited in 1 Hawaii opinions naming this issue, 1998–1998
2 sentences

1998Co., 82 Hawai'i 120, 132 , 920 P.2d 334, 346 (1996), we held that “there is a legal duty, implied in a first-and third-party insurance contract, that the insurer must act in good faith in dealing with its insured, and a breach of that duty of good faith gives rise to an independent tort cause of action.” We are of the view that, where an insurer is required to provide a defense for its insured, it would be a breach of the duty of good faith to induce retained counsel to provide a defense which did not meet the professional standard set forth by the HRPC.

1998Co., 82 Hawai'i 120, 132 , 920 P.2d 334, 346 (1996), we held that “there is a legal duty, implied in a first-and third-party insurance contract, that the insurer must act in good faith in dealing with its insured, and a breach of that duty of good faith gives rise to an independent tort cause of action.” We are of the view that, where an insurer is required to provide a defense for its insured, it would be a breach of the duty of good faith to induce retained counsel to provide a defense which did not meet the professional standard set forth by the HRPC.

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 (5)

CaseCitedYears
Finley v. Home Insurance Co. green
haw · 1998
2 sentences

2016This court has held that “where an insurer is required to provide a defense for its insured, it would be a breach of the duty of good faith to induce retained counsel to provide a defense which did not meet the professional standard set forth by the [Hawai'i Rules of Professional Conduct].” Finley, 90 Hawai'i at 36 , 975 P.2d at 1156 .

2016This court has held that “where an insurer is required to provide a defense for its insured, it would be a breach of the duty of good faith to induce retained counsel to provide a defense which did not meet the professional standard set forth by the [Hawai'i Rules of Professional Conduct].” Finley, 90 Hawai'i at 36 , 975 P.2d at 1156 .

22014–2016
State v. Valdivia green
haw · 2001
2 sentences

2006On appeal after conviction, the defendant argued that the trial court erroneously failed, over his objection, to instruct the jury that “[w]here a threat is directed at a police officer, you may consider that police officers are trained to a professional standard of behavior that ordinary citizens might not be expected to equal.” Id. at 479 , 24 P.3d at 675 .

2006On appeal after conviction, the defendant argued that the trial court erroneously failed, over his objection, to instruct the jury that "[w]here a threat is directed at a police officer, you may consider that police officers are trained to a professional standard of behavior that ordinary citizens might not be expected to equal." Id. at 479, 24 P.3d at 675 .

12006–2006
Mulder v. Parke Davis & Company green
minn · 1970
2 sentences

1995Id. at 339-40 , 181 N.W.2d at 887 . 16 Ohligschlager v. Proctor Community Hosp., 55 Ill.2d 411 , 303 N.E.2d 392 (1973), adopted Mulder , and held that the explicit instructions provided by the manufacturer *? warning of the hazards accompanying improper administration of the drug provided prima facie proof of the professional standard for the drug’s use, which would ordinarily have to be shown by expert medical testimony.

1995Id. at 339-40 , 181 N.W.2d at 887 . 16 Ohligschlager v. Proctor Community Hosp., 55 Ill.2d 411 , 303 N.E.2d 392 (1973), adopted Mulder , and held that the explicit instructions provided by the manufacturer *? warning of the hazards accompanying improper administration of the drug provided prima facie proof of the professional standard for the drug’s use, which would ordinarily have to be shown by expert medical testimony.

11995–1995
Ohligschlager v. Proctor Community Hospital green
ill · 1973
2 sentences

1995Id. at 339-40 , 181 N.W.2d at 887 . 16 Ohligschlager v. Proctor Community Hosp., 55 Ill.2d 411 , 303 N.E.2d 392 (1973), adopted Mulder , and held that the explicit instructions provided by the manufacturer *? warning of the hazards accompanying improper administration of the drug provided prima facie proof of the professional standard for the drug’s use, which would ordinarily have to be shown by expert medical testimony.

1995Id. at 339-40 , 181 N.W.2d at 887 . 16 Ohligschlager v. Proctor Community Hosp., 55 Ill.2d 411 , 303 N.E.2d 392 (1973), adopted Mulder , and held that the explicit instructions provided by the manufacturer *? warning of the hazards accompanying improper administration of the drug provided prima facie proof of the professional standard for the drug’s use, which would ordinarily have to be shown by expert medical testimony.

11995–1995
Young v. Price green
haw · 1964
2 sentences

1968We feel compelled to state that, even if the incompetent testimony elicited from the plaintiff had been much less detrimental to defendants than it was, we would not, on the trial record of this case, allow the error to stand and thus set a precedent that might be taken as militating against the professional standard of candor which proscribes an attorney from getting evidence before a jury which he knows or should know the court should reject. 48 Haw. at 28 , 395 P.2d at 369 .

1968We feel compelled to state that, even if the incompetent testimony elicited from the plaintiff had been much less detrimental to defendants than it was, we would not, on the trial record of this case, allow the error to stand and thus set a precedent that might be taken as militating against the professional standard of candor which proscribes an attorney from getting evidence before a jury which he knows or should know the court should reject. 48 Haw. at 28 , 395 P.2d at 369 .

11968–1968

Where else courts name it

CA 80 (1979–2026) IL 48 (1969–2026) GA 29 (1984–2024) TX 28 (1977–2023) NY 25 (1914–2019) NJ 22 (1979–2026) PA 15 (1986–2025) IA 14 (1979–2026) FL 14 (1991–2026) MD 14 (1977–2018) NC 13 (1979–2023) WA 12 (2004–2025) TN 12 (1991–2025) MI 12 (1936–2026) CO 12 (1982–2026) LA 10 (1978–2016) WI 9 (1985–2018) HI 9 (1968–2020) OR 9 (1985–2023) AZ 9 (1976–2019) OH 9 (1997–2016) CT 9 (1993–2015) SC 9 (1984–2010) NV 9 (1980–2021) NM 7 (1998–2024) MS 7 (1986–2007) SD 7 (1985–2025) VA 6 (1979–2025) MN 6 (1930–2016) KY 5 (1992–2020) MO 5 (2008–2024) WY 5 (1992–2014) ND 5 (1992–2004) IN 4 (1986–2024) AL 4 (1990–2011) UT 4 (1987–2023) DE 4 (1977–2025) VT 4 (2011–2025) AK 4 (1980–2021) MA 4 (2009–2025) ME 4 (2001–2021) OK 3 (2012–2016) KS 3 (1987–2005) DC 2 (1982–2002) NE 2 (1987–2023)

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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