Cushnie v. Nago

CourtHawaii Supreme Court
DecidedDecember 20, 2024
DocketSCEC-24-0000797
StatusPublished

This text of Cushnie v. Nago (Cushnie v. Nago) is published on Counsel Stack Legal Research, covering Hawaii Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cushnie v. Nago, (haw 2024).

Opinion

Electronically Filed Supreme Court SCEC-XX-XXXXXXX 20-DEC-2024 02:45 PM Dkt. 43 FFCL

SCEC-XX-XXXXXXX

IN THE SUPREME COURT OF THE STATE OF HAWAIʻI ________________________________________________________________

RALPH S. CUSHNIE and more than THIRTY VOTERS, Plaintiffs,

vs.

SCOTT NAGO, as Chief Elections Officer for the Office of Elections, State of Hawaiʻi; and JADE FOUNTAIN-TANIGAWA, County Clerk for the County of Kauaʻi, Defendants. ________________________________________________________________

ORIGINAL PROCEEDING

FINDINGS OF FACT, CONCLUSIONS OF LAW, AND JUDGMENT (By: Recktenwald, C.J., McKenna, Eddins, Ginoza, and Devens, JJ.)

This 2024 General Election contest is about overages. An

overage occurs when the amount of ballots recorded in the

official election results is more than what “documented usage”

indicates.

Plaintiffs Ralph Cushnie (Cushnie) and thirty-two other

voters (collectively, Plaintiffs) assert there is an overage in

mail ballots that are sufficient in quantity to cause a

difference in the results of the Kauaʻi County Councilmember race

in the 2024 General Election. However, the data that Plaintiffs rely on for “documented

usage” contains a disclaimer that expressly states that the

figures represent a manual count of envelopes and not the number

of ballots counted. It is unreasonable to infer a ballot count

from this data due to this disclaimer.

Plaintiffs’ December 12, 2024 Memorandum in Support also

concedes that there is a difference of only 39 ballots when

comparing Plaintiffs’ 27,036 envelope amount that was

transferred to the state counting center and the 27,075 total

mail ballots from the official results of the 2024 General

Election in Kauaʻi County. This 39 ballot difference is less

than the 108 vote difference between the seventh place and

eighth place candidates in the 2024 General Election race for

Kauaʻi County Councilmember.

We thus enter the following findings, conclusions, and

Judgment in favor of the State and County, and against

Plaintiffs. We also deny Plaintiffs’ motion for

interrogatories.

I. FINDINGS OF FACT

According to the final printout, the 2024 General Election

results for the Kauaʻi County Councilmember race were:

1. CARVALHO, Bernard P., Jr. 15,435 7.2% 2. RAPOZO, Mel 14,403 6.7% 3. KANESHIRO, Arryl J. 13,049 6.1%

2 4. BULOSAN, Addison 12,385 5.8% 5. COWDEN, Felicia 12,325 5.8% 6. KUALII, KipuKai 12,276 5.7% 7. HOLLAND, Fern Anuenue 12,041 5.6% KAGAWA, Ross 11,933 5.6% DECOSTA, Billy D. 9,977 4.7% APILADO, Abe, Jr. (Aba-G) 5,964 2.8% KEAHIOLALO, W. Butch 5,202 2.4% CUMMINGS, Sherri 4,160 1.9% NELSON, Jacquelyn (Jakki) 3,386 1.6% THOMAS, Bart 3,296 1.5% Blank Votes: 77,696 36.4% Over Votes: 62 0.0%

A voter may vote for up to seven candidates in this race.

Numbers are added to the above results to clearly identify the

top seven candidates.

There is a 108 vote difference between the seventh-place

candidate (Fern Anuenue Holland) and eighth place candidate

(Ross Kagawa).

There were a total 27,075 mail ballots that were recorded

in the final printout of the official 2024 General Election

results for Kauaʻi County.

On November 25, 2024, Plaintiffs filed an Election

Complaint (Complaint) asserting there is an “overage of 3,772

voted ballots” that caused a difference in the 2024 General

Election results for the Kauaʻi County Councilmember race.

Plaintiffs assert that a correct result cannot be determined for

3 this election “due to the provable overage,” and this court’s

Judgment should invalidate the results of the Kauaʻi County

Councilmember race.

Plaintiffs submitted an information request under the

Uniform Information Practices Act to the Kauaʻi County Elections

Division for chain-of-custody documentation relating to ballot

collections and handling for the 2024 General Election.

Based on the information provided by County, Plaintiffs

assert that the “documented usage for voted ballot envelopes was

recorded as 23,303, and is the total number of voted ballots

submitted by mail for the county.” Plaintiffs assert their

23,303 number constitutes the “documented usage” for purposes of

calculating an overage of mail ballots pursuant to Hawaiʻi

Revised Statutes (HRS) § 11-153(a) (Supps. 2019 & 2021), Hawaiʻi

Administrative Rules (HAR) § 3-177-750 (eff. 2020), and HAR § 3-

177-769(b) (eff. 2020).

The documents attached to the Complaint that support

Plaintiffs’ 23,303 number all contain the following “Disclaimer”

at the bottom of each page:

Figures on this form represent a manual count of envelopes - not the number of ballots counted. The manual counts were made for internal purposes to track election progress with the understanding that it would not match official election results.

Subtracting Plaintiffs’ 23,303 figure from the total 27,075

mail ballots in Kauaʻi County results in an overage of 3,772 mail

4 ballots. Plaintiffs assert that this 3,772 overage amount

“cause[d] a difference in the election results for the county

council race for the County of Kauai” because the “overage of

3,772 voted ballots exceeds the reported margin between

candidates for the top nine candidates” in the Kauaʻi County

Plaintiffs’ Complaint was signed by Cushnie and includes

the signatures of Cushnie and thirty-two other voters from

“Kauai District 17” under the following affirmation:

I am one of more than thirty voters from Kauai District 17 and am filing this election complaint pursuant to the Constitution for the State of Hawaii and Hawaii Revised Statutes for redress of grievances regarding the 2024 Hawaii General Election and as per the accompanying filing.

Motions to dismiss or for summary judgment were filed by

Defendant Jade Fountain-Tanigawa, County Clerk for the County of

Kauaʻi (County), on December 4, 2024, and Defendant Scott Nago,

Chief Elections Officer for the Office of Elections (the State

or Nago), on December 5, 2024.

County’s motion asserts that the data that Plaintiffs used

to calculate the 3,772 overage ballot amount is wrong because

Plaintiffs’ data is based on ballot envelopes rather than

ballots themselves, and the County “forms capturing ballot

envelope counts are not used to calculate overages and underages

pursuant to HRS § 11-153.” Pointing to the Disclaimer at the

5 bottom of the County forms, County states that its forms

capturing ballot envelope counts are used by County to

approximate the quantity of ballot envelopes collected and the quantity still outstanding and was meant to aide with projecting staffing needs and scheduling of staff overtime, with the understanding that the envelope counts would not equal the quantity of ballots counted and reported in official election results.

County also asserts that Plaintiffs miscalculated the

ballot envelope amount due to missing data, and provided the

missing data through Exhibit A to County’s motion.

The State’s motion to dismiss or for summary judgment

asserts: (A) the Complaint should be dismissed for lack of

standing pursuant to Cordery v. Ige, SCEC-XX-XXXXXXX, because

Cushnie is the only Plaintiff, or voter, in this election

contest; (B) Plaintiffs disregard the disclaimer language on the

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Cushnie v. Nago, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cushnie-v-nago-haw-2024.