Alexander & Baldwin, Inc. v. Silva
Hawaii Intermediate Court of Appeals · 2011-01-11 · cited 6×
The case involved a quiet title action filed by Alexander & Baldwin against multiple defendants, including Keith Silva, seeking to establish sole ownership of three parcels of land in Koloa, Hawaii, based on Land Commission Awards. Silva claimed interests in the parcels through inheritance and deeds. The appellate court held that the trial court erred in granting partial summary judgment against Silva on two parcels, as A&B failed to meet its initial burden of production to show no genuine issue of material fact regarding Silva's claimed interests, and A&B had not submitted evidence of its own title. The court clarified that in quiet title actions, the plaintiff bears the burden of production on the defendant's interest even without first establishing its prima facie title, that findings of fact are not required on summary judgment, and that disputed facts remained, leading to vacation of the judgment and remand.