Rubalcaba v. Association of Apartment Owners of Makakilo Cliffs

The case involves Juan Angel Rubalcaba, a homeowner, who filed a wrongful foreclosure lawsuit against the Association of Apartment Owners of Makakilo Cliffs. The central issue was whether the mortgage debt of the homeowner to a third-party lender, which was discharged by the third-party lender's subsequent foreclosure, should be considered in determining the plaintiff's damages.

The Circuit Court of the First Circuit sought guidance on this issue and forwarded a reserved question to the Supreme Court of the State of Hawai'i. The Supreme Court accepted the question, indicating that it would provide an answer through a related case, Wong v. Ass'n of Apartment Owners of Harbor Square, which was then pending before the court.

The Supreme Court of the State of Hawai'i, after deciding the Wong case, provided guidance on how a plaintiff may calculate damages in a lawsuit against a condominium association for wrongful foreclosure. The court then remanded the case back to the Circuit Court of the First Circuit for further proceedings consistent with the Wong decision. The court did not provide a specific ruling on the reserved question but indicated that the lower court should follow the precedent set in the Wong case.