Nelson v. Hawaiian Homes CommissionAnnotate this Case
The circuit court erred by engaging in a comprehensive inquiry into the amount the Department of Hawaiian Home Lands (DHHL) actually needed for its administrative and operating expenses.
In the first appeal in this case, the Supreme Court held that the political question doctrine did not bar a judicial interpretation of the meaning of “sufficient sums” for the DHHL administrative and operating expense, pursuant to Haw. Const. art. XII, 1. On remand, the circuit court concluded that DHHL’s actual need for its administrative and operating expenses was more than $28 million and that the legislature was constitutionally obligated to make such an appropriation to DHHL for fiscal year 2015-16. The court also enjoined the State and its director of finance from violating the constitution or breaching their fiduciary duties to Hawaiian Homelands trust beneficiaries. The Supreme Court vacated the circuit court’s final judgment and underlying orders, holding that the circuit court exceeded this court’s mandate in Nelson I when it determined the amount DHHL actually needed for its administrative and operating expenses.