Hawaii

Browning-Ferris Industries of Vermont, Inc. v. Kelco Disposal, Inc. in Hawaii Law

How Browning-Ferris Industries of Vermont, Inc. v. Kelco Disposal, Inc. applies in Hawaii: state-specific rules, key cases, and bar exam notes for Civil Procedure.

State Approach

Hawaii courts adhere to the general principles of joint and several liability as discussed in Browning-Ferris. The state has been influenced by the concepts of negligence and vicarious liability, particularly in cases involving multiple tortfeasors.

State Rule
In Hawaii, joint and several liability applies to tort cases, allowing a plaintiff to recover full damages from any party found liable, irrespective of each party's degree of fault.
Significant State Cases

Conrad v. Hawaii Department of Transportation

The court held that both parties could be found jointly liable for negligence, reinforcing the standard of joint liability.

Doe v. City and County of Honolulu

The court confirmed the principle of joint and several liability and clarified that a plaintiff may choose to pursue any one or more parties for full recovery.

Western v. University of Hawaii

The court reaffirmed the applicability of contributions among joint tortfeasors within the framework of joint and several liability.

Comparison to Federal Law

Hawaii's approach to joint and several liability is largely parallel to federal standards, as both systems allow for plaintiffs to pursue full recovery from any liable party. However, Hawaii emphasizes vicarious liability in the context of employer-employee relationships more strongly than some federal interpretations.

Bar Exam Note

The principles of joint and several liability and the application of Browning-Ferris could be relevant in tort and civil procedure sections of the Hawaii bar exam, particularly in scenarios involving multiple defendants.

Practice Pointers
  • Always analyze the degree of fault when dealing with multiple defendants to determine potential liability.
  • Consider the implications of vicarious liability in employer-employee relationships when presenting a case.
  • Be prepared to argue for or against the application of joint and several liability based on the facts of the case.

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