Santiago v. Mauna Loa Invs., LLC

Petitioner filed suit against Mauna Loa Investments, LLC alleging that she was injured when she fell on property owned, maintained, and/or controlled by Mauna at the time of the injury. The trial court entered a default judgment against Mauna. Petitioner subsequently filed a complaint in a separate action against Iberia NV, LLC, alleging that she was injured on the same property and alleging that Iberia owned, maintained, and/or controlled the property at the time of the injury. The Iberia case was consolidated with Petitioner’s suit against Mauna. Mauna filed an amended motion to set aside the default, alleging that the Iberia complaint constituted Plaintiff’s admission that her prior allegations in the Mauna complaint were false. Thereafter, Petitioner voluntarily dismissed without prejudice the Iberia complaint. The circuit court ultimately denied Mauna’s motion. After a jury trial solely on damages, the jury found for Petitioner. The Court of Appeal reversed the judgment and vacated the default, concluding that Petitioner’s Mauna complaint failed to state a cause of action. The district court reached its conclusion based on its consideration of the complaint in the Iberia case. The Supreme Court reversed, holding that the district court erred in considering documents outside the complaint in determining the complaint’s sufficiency to state a cause of action. View "Santiago v. Mauna Loa Invs., LLC" on Justia Law