The Hawaii Intermediate Court of Appeals issued a significant ruling on May 27, 2026, in the case of Gordon Knowles v. Hawaii Pacific University (HPU). The court decided to vacate the attorney fees awarded to HPU after Knowles's claims were dismissed, which could have broader implications for employment disputes and whistleblower protections in Hawaii.

This ruling directly affects Gordon Knowles, a former professor at HPU, who claimed that his termination was unjust and retaliatory. The decision also has ramifications for HPU and potentially for other employers in similar situations, as it addresses the limits of attorney fee awards in cases involving employment contracts and whistleblower claims.

Background

Gordon Knowles served as a full-time professor at HPU until his employment was terminated in June 2015. His dismissal stemmed from allegations of violating HPU's Conflict of Interest Policy by teaching at other institutions without disclosure. Knowles contended that he was being unfairly targeted and even claimed he was being stalked, which he believed contributed to his dismissal.

In December 2016, Knowles filed a complaint in federal court, alleging retaliation under Title VII of the Civil Rights Act and violations of the Hawaii Whistleblower Protection Act (HWPA), along with breach of contract. The federal court dismissed his claims, leading Knowles to file a two-count complaint against HPU in the Circuit Court of the First Circuit in August 2018, where he sought damages for breach of contract and violation of the HWPA.

The Circuit Court held a bench trial in October 2023, but ruled against Knowles on all counts. Following this, HPU filed a motion for attorney fees, claiming over $258,000, which Knowles contested, arguing that the fees should be limited and apportioned appropriately between the claims. The Circuit Court ultimately awarded HPU $180,583.50 in attorney fees, prompting Knowles to appeal.

The Ruling

The Hawaii Intermediate Court of Appeals reviewed the case and found that the Circuit Court had abused its discretion in awarding attorney fees to HPU. The court stated, "it is an abuse of discretion to award the employer-defendant attorneys' fees in excess of the amount allowable on the claim in the nature of assumpsit." The court emphasized the need to limit attorney fees to maintain fairness in the legal process.

The ruling clarified the standards for awarding attorney fees, particularly in cases that involve both contract claims and statutory claims such as those under the HWPA. The court noted that although Knowles's claims were intertwined, the fees awarded should not exceed the potential damages Knowles could have recovered under his breach of contract claim. This was based on legislative intent to prevent excessive attorney fees and to uphold principles of fairness in employment disputes.

Impact

This decision could have significant implications for future employment-related cases in Hawaii. By emphasizing limits on attorney fees, the court aims to protect employees, particularly whistleblowers, from the chilling effect that excessive legal costs could impose on their willingness to report violations. The ruling reinforces the principle that attorney fees should be proportionate to the claims at issue, thus discouraging employers from pursuing punitive legal strategies against former employees.

Furthermore, the ruling sets a precedent regarding the intersection of contract law and whistleblower protections. It clarifies that while employers may seek to recover attorney fees in cases where they prevail, those fees should be capped based on the potential damages related to the claims brought by the plaintiff. This could encourage more individuals to assert their rights under whistleblower laws, knowing that the financial risks associated with legal battles are more manageable.

What's Next

The case has been remanded to the Circuit Court for a recalculation of the attorney fees awarded to HPU, consistent with the appellate court's opinion. Details on whether Knowles plans to pursue additional claims or if HPU will adjust its approach in light of this ruling were not available in the court filing.