In United Here! Local 5 v. City and County of Honolulu, No. 28602 (May 22, 2009), the Hawaii Intermediate Court of Appeals held that a developer need not undertake a Supplemental Environmental Impact Statement under the Hawaii Environmental Policy Act, Haw. Rev. Stat. ch. 343, unless the plaintiff shows a substantive change in the project being reviewed.
The April 9, 2009 oral arguments are posted here.