Jared Armstrong, Appellant v. James Matthew Tanaka, Appellee

Summary

The court held that when a civil plaintiff faces related criminal charges and seeks a stay to protect the privilege against self-incrimination, the trial court must expressly balance the plaintiff's constitutional interests against the civil defendant's interests in defending the case and obtaining timely resolution. Because the superior court did not apply that balancing test and had ordered Armstrong to answer questions potentially implicating his privilege, the court vacated the stay denial, dismissal, and attorney's-fee award and remanded. The court did not reach Armstrong's unresolved request for discovery from the police department.