## Facts

- Jerry Fukida brought his 1986 Honda Civic to an automotive repair shop operated by the defendants for a safety check and transmission assessment.
- After diagnosing transmission problems, defendants advised that a rebuilt transmission was needed.
- Fukida authorized installation of a rebuilt transmission on the express condition that he be allowed to inspect it before installation.
- Defendants installed the rebuilt transmission without notifying Fukida or allowing inspection.
- When Fukida refused to pay, defendants refused to return the vehicle, asserted a repair lien, and later imposed storage charges.
- The trial court found the lien was unlawfully imposed on June 2, 1996, and that defendants retained the vehicle until August 29, 1998, depriving Fukida of its use for more than two years.
- The district court awarded Fukida $6,970 in general damages for loss of use, plus attorney’s fees and costs, holding defendants jointly and severally liable.

## Issues

1. Whether loss-of-use damages for wrongful deprivation of a vehicle’s use are categorically limited, as a matter of law, to no more than the vehicle’s market value.
2. What constraints govern the duration and amount of loss-of-use damages when a defendant wrongfully detains property.

## Decision

- The Hawaiʻi Supreme Court granted certiorari to review the Intermediate Court of Appeals’ holding that loss-of-use damages cannot exceed the vehicle’s value.
- The court rejected a per se cap on loss-of-use damages at the vehicle’s market value.
- The court reversed the ICA in part and remanded to the district court for entry of a second amended judgment consistent with the court’s analysis and the prior appellate rulings.

## Legal Principles

- Loss-of-use damages are compensatory general damages for being wrongfully deprived of the use of one’s property.
- Loss-of-use damages are not automatically limited to the market value of the detained property; the factfinder must determine reasonable compensation based on the evidence and the period of deprivation.
- Recovery remains constrained by traditional limits, including proximate causation, reasonable certainty of proof, foreseeability, reasonableness, and the duty to mitigate damages through reasonable diligence.
- A categorical cap based solely on property value is inconsistent with compensatory principles where wrongful detention continues for an extended period and results in continuing harm.

## Conclusion

The Hawaiʻi Supreme Court held that loss-of-use damages for wrongful detention of a vehicle are not capped at the vehicle’s market value as a matter of law; instead, damages may extend through the period of deprivation if supported by evidence and limited by causation, reasonableness, and mitigation, and the case was remanded for judgment without applying a per se cap.


Fukida v. Hon/Haw. Serv. & Repair, 97 Haw. 38, 33 P.3d 204 (2001)