Gatri v. Blane’s Empirical Analysis
1998
Citation profile
14 state decisions
How this case has been cited
Cited by 14 later decisions — most recently April 2013
14 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Kona Old Hawaiian Trails Group Ex Rel. Serrano v. Lyman · State v. Ganal · Konno v. County of Hawai'i · Hawai'i's Thousand Friends v. City & County of Honolulu · Poe v. Hawai'i Labor Relations Board
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) In violation of constitutional or statutory provisions; or (2) In excess of the statutory authority or jurisdiction of the agency; or (3) Made upon unlawful procedure; or (4) Affected by other error of law; or (5) Clearly erroneous in view of the reliable, probative, and substantial evidence on the whole record; or (6) Arbitrary, or capricious, or characterized by abuse of discretion or clearly unwarranted exercise of discretion.”
6 later decisions quote this exact passage“In Thousand Friends, we distinguished Kona because of the different language contained in the Revised Charter of the City and County of Honolulu. The Honolulu charter established a procedure for appeals from actions of the Department of Land Utilization (DLU) to the Zoning Board of Appeals only for those DLU actions concerning “the administration of the zoning and subdivision ordinances and any rules and regulations adopted pursuant thereto.” Thousand Friends, 75 Haw. at [242], 858 P.2d at [729-30]. The challenged action involved an environmental group’s petition for a declaration that the City had to obtain a SMA permit for its proposed demolition of structures within the coastal zone management area. The Honolulu charter did not specifically provide for appeals of declaratory judgments regarding the necessity for obtaining a SMA permit. Therefore, we held that the circuit court had jurisdiction to entertain a direct appeal of the DLU action.”
1 later decision quote this exact passage“There is no express procedure provided in the Maui charter or the Maui SMA rules for an appeal of the Director’s decision on a minor permit application to the Commission. The Commission [under Maui SMA rules § 12-202-14] has delegated the authority to render a final decision on a minor permit application to the Director. The Director is required to notify the Commission of permits which he has granted. Based on [Hawaii’s Thousand Friends v. City and County of Honolulu, 75 Haw. 237 , 858 P.2d 726 (1993) ], we hold that, under this scheme, the circuit court had jurisdiction over this appeal of a final decision of the Director. Therefore, GA-TRI exhausted its administrative remedies.”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.