Hawaii Case Commentaries

State v. Tolentino (Haw. 2026): Mandatory Pretrial Evidentiary Voluntariness Hearings for Inculpatory Statements; New-Trial Remedy; Partial Overruling of State v. Goers

Date: Jul 4, 2026

Hawaiʻi’s Mandatory Pretrial Evidentiary Voluntariness Hearing Rule for Inculpatory Statements (and the New-Trial Remedy), with State v. Goers Partially Overruled I. Introduction In State v....

HRS § 291C-12(a) “Involved in a Collision” Includes Non-Contact Pursuit; Vagueness Challenges Are As-Applied Only; Bill of Particulars Can Supply Constitutionally Adequate Notice

Date: Jul 3, 2026

HRS § 291C-12(a) “Involved in a Collision” Includes Non-Contact Pursuit; Vagueness Challenges Are As-Applied Only; Bill of Particulars Can Supply Constitutionally Adequate Notice Case: State v....

Summary Judgment in Title-Contested Trespass Requires Deraignment of Title; Unchallenged Summary-Judgment Findings Are Not Binding on Appeal

Date: Jul 2, 2026

Summary Judgment in Title-Contested Trespass Requires Deraignment of Title; Unchallenged Summary-Judgment Findings Are Not Binding on Appeal I. Introduction In ATC Makena N Golf LLC v. Kaiama (Haw....

“In Means In”: HRS § 711-1110.9(1)(a) Requires the Recording Device (or Its Use) to Occur Inside the Private Place

Date: Jun 23, 2026

“In Means In”: HRS § 711-1110.9(1)(a) Requires the Recording Device (or Its Use) to Occur Inside the Private Place Case: State v. Kaakimaka (Haw. Sup. Ct. June 22, 2026, SCWC-22-0000690) (opinion by...

Preston v. Hiraoka: Meaningful Appellate Review Requires Kelepolo-Based Consideration of Bond or Alternative Security to Stay Ejectment Possession Judgments

Date: Jun 22, 2026

Preston v. Hiraoka: Meaningful Appellate Review Requires Kelepolo-Based Consideration of Bond or Alternative Security to Stay Ejectment Possession Judgments I. Introduction Preston v. Hiraoka (Haw....

Hawaiʻi Guardianship Termination: Parental Presumption Survives Consent; Unfitness Requires Clear and Convincing Proof

Date: Jun 22, 2026

Hawaiʻi Guardianship Termination: Parental Presumption Survives Consent; Unfitness Requires Clear and Convincing Proof Case: In the Matter of the Guardianship of I.W. and T.E., SCWC-23-0000356 (Haw....

State v. Jercy: Show-Up Identifications Must Be Evaluated Under HAWJIC 3.19A and the Effect of Suggestiveness, with Suppression Required When the Record Shows Unreliability

Date: Jun 18, 2026

State v. Jercy: Show-Up Identifications Must Be Evaluated Under HAWJIC 3.19A and the Effect of Suggestiveness, with Suppression Required When the Record Shows Unreliability 1. Introduction State v....

Unambiguous Video Evidence Limits “Reasonably Susceptible” Inferences at Summary Judgment in Hawaiʻi

Date: Jun 8, 2026

Unambiguous Video Evidence Limits “Reasonably Susceptible” Inferences at Summary Judgment in Hawaiʻi I. Introduction Bellamy v. City and County of Honolulu (Haw. June 5, 2026) is a...

Premature Termination Before a Set Corrective-Action Deadline Does Not Prove “Misconduct” Disqualifying Hawaiʻi Unemployment Benefits

Date: Jun 7, 2026

Premature Termination Before a Set Corrective-Action Deadline Does Not Prove “Misconduct” Disqualifying Hawaiʻi Unemployment Benefits Introduction Choi v. Tachibana Enterprises, LLC (Hawaiʻi Supreme...

State v. Ellway: Mid‑Evidence Judge Replacement in a Criminal Bench Trial Ends the First Trial and Triggers Double Jeopardy Absent a Proper Mistrial

Date: Jun 7, 2026

State v. Ellway: Mid‑Evidence Judge Replacement in a Criminal Bench Trial Ends the First Trial and Triggers Double Jeopardy Absent a Proper Mistrial I. Introduction In State v. Ellway (Haw. June 5,...

“Good Cause” for Untimely Intervention Before the Maui Planning Commission Means a “Sufficient Reason,” Not the Chen v. Mah Default Standard

Date: May 24, 2026

“Good Cause” for Untimely Intervention Before the Maui Planning Commission Means a “Sufficient Reason,” Not the Chen v. Mah Default Standard Gutschmidt v. Maui Planning Commission (Haw. May 22, 2026)...

JK v. HK (Haw. 2026): Gender-Neutral “Holding Out” Presumption Establishes Parentage for Unmarried, Nonbiological Parents Under the 1973 UPA

Date: May 20, 2026

Gender-Neutral “Holding Out” Presumption Establishes Parentage for Unmarried, Nonbiological Parents Under the 1973 UPA 1. Introduction In JK v. HK (Supreme Court of Hawaiʻi, May 18, 2026), the court...

State v. Wilhelm: Harmless-Error Treatment of a Late Voluntariness Determination Under HRS § 621-26

Date: May 20, 2026

State v. Wilhelm: Harmless-Error Treatment of a Late Voluntariness Determination Under HRS § 621-26 Court: Intermediate Court of Appeals of the State of Hawaiʻi (Summary Disposition Order; Not for...

Private Attorney General Fees Do Not Require Additional Remedial Relief Beyond a Merits Victory (Ralston v. BLNR)

Date: May 19, 2026

Private Attorney General Fees Do Not Require Additional Remedial Relief Beyond a Merits Victory: Fee Eligibility After an Appellate Holding That Due Process Required a Contested Case Hearing Case:...

Bolos v. Waldorf=Astoria Management LLC — Hawaiʻi Minimum Wage Is Measured Per Hour, Not Averaged Per Workweek

Date: May 11, 2026

Hawaiʻi Minimum Wage Compliance and Damages Must Be Measured “Per Hour,” Rejecting Workweek Averaging Under HRS §§ 387-2 and 387-12 1. Introduction In Bolos v. Waldorf=Astoria Management LLC (Supreme...

Informal Agency Memoranda that Alter Substantive Rights Are “Rules”; Untimely Procedural Challenges Are Barred, but Timely Objectors Cannot Be Bound by Unpromulgated Changes

Date: May 5, 2026

Informal Agency Memoranda that Alter Substantive Rights Are “Rules”; Untimely Procedural Challenges Are Barred, but Timely Objectors Cannot Be Bound by Unpromulgated Changes 1. Introduction In Martel...

State v. Bunag: Consecutive Sentencing Requires Contemporaneous, Court-Stated Reasons—No Post-Hoc Orders and No Prosecutor “Parroting”

Date: Apr 24, 2026

State v. Bunag: Consecutive Sentencing Requires Contemporaneous, Court-Stated Reasons—No Post-Hoc Orders and No Prosecutor “Parroting” I. Introduction In State v. Bunag (Haw. Apr. 20, 2026), the...

Temporary Support and Child Support May Rely on Regular Pre-Filing Trust Distributions; Expected Continued Trust Access Can Be a VARC for Property Division

Date: Mar 28, 2026

Temporary Support and Child Support May Rely on Regular Pre-Filing Trust Distributions; Expected Continued Trust Access Can Be a VARC for Property Division Case: A.P. v. S.B. | Court: Intermediate...

Escrow Depository’s Fiduciary Duty Is Satisfied by Strict Compliance with an Unambiguous Escrow Agreement—even if the Sales Contract Would Require a Refund

Date: Mar 22, 2026

Escrow Depository’s Fiduciary Duty Is Satisfied by Strict Compliance with an Unambiguous Escrow Agreement—even if the Sales Contract Would Require a Refund I. Introduction Case: Yamaguchi v. Title...

Greenspon: “Fraud on the Court” Against Opposing Counsel Requires Egregious, Particularized Misconduct; Vexatious-Litigant Orders Sustainable on Record of Delay and Prior Out-of-State Designation

Date: Feb 15, 2026

“Fraud on the Court” Claims Against Opposing Counsel Demand a High, Particularized Showing of Egregious Misconduct (and Courts Must Screen Sufficiency at the Pleading Stage) Case: Greenspon v....