Dicks v. State

557 P.3d 831, 155 Haw. 102
CourtHawaii Supreme Court
DecidedJuly 25, 2024
DocketSCEC-24-0000474
StatusPublished
Cited by1 cases

This text of 557 P.3d 831 (Dicks v. State) 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
Dicks v. State, 557 P.3d 831, 155 Haw. 102 (haw 2024).

Opinion

*** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

Electronically Filed Supreme Court SCEC-XX-XXXXXXX 25-JUL-2024 12:02 PM Dkt. 30 OPPC

IN THE SUPREME COURT OF THE STATE OF HAWAIʻI

---o0o---

KARL ORLANDO DICKS, Plaintiff,

vs.

STATE OF HAWAIʻI, OFFICE OF ELECTIONS; SCOTT NAGO, Chief Election Officer, State of Hawaiʻi, Defendants.

SCEC-XX-XXXXXXX

ORIGINAL PROCEEDING

JULY 25, 2024

RECKTENWALD, C.J., McKENNA, EDDINS, GINOZA, AND DEVENS, JJ.

PER CURIAM

In this election contest, filed before the election results

have even posted, a nonpartisan candidate alleges that the

primary election ballots suffer from constitutional and

statutory infirmities. We disagree.

For the reasons discussed, we dismiss all election contest

claims for failure to state a claim. We also liberally construe *** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

the complaint as seeking a petition for a writ of mandamus

directed to a public officer, and deny the petition.

I. Background

On July 11, 2024, Plaintiff Karl Orlando Dicks filed a

complaint challenging the primary election ballot’s requirement

that the voter select a political preference to vote. Plaintiff

claims the primary ballot violates article II, section 4 of the

Hawaiʻi Constitution and Hawaiʻi Revised Statutes (HRS) §§ 12-21,

12-31, and 12-42 (2009), and citing to HRS §§ 11-172 (Supp.

2021), 11-173.5 (2009 & Supp. 2023), 11-174.5 (2009 & Supp.

2021), 91-14 (2012 & Supp. 2016) and 602-5 (2016), he seeks an

order directing Defendants to design a ballot that conforms to

the law and to declare the current ballot invalid.

On July 16, 2024, Defendants State of Hawaiʻi, Office of

Elections and Scott Nago, in his official capacity as Chief

Election Officer of the State of Hawaiʻi, moved to dismiss the

complaint for failure to state a claim or lack of jurisdiction.

II. Discussion

A. Plaintiff’s claims under HRS §§ 11-173.5, 11-174.5 and 91-14, are dismissed

Defendants moved to dismiss the complaint for failure to

state a claim.

Dismissal of a claim is appropriate where the plaintiff can

prove no set of facts in support of a claim to be entitled to

2 *** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

relief. See Bank of Am., N.A. v. Reyes-Toledo, 143 Hawaiʻi 249,

258, 428 P.3d 761, 770 (2018).

HRS § 11-173.5 applies to primary election contests, and

the relief available is for this court to enter a judgment that

decides which candidate was nominated or elected. See HRS § 11-

173.5(b). Under HRS § 11-174.5, for a general election the

remedies available are for this court to decide which candidate

was elected, or to invalidate the election when the correct

result cannot be ascertained. Thus, to state a claim to relief

under HRS §§ 11-173.5 and 11-174.5, the complaint must plead

that election results have posted.

Here, the complaint fails to state a claim under HRS §§ 11-

173.5 and 11-174.5 because no posted election results are

challenged. In addition, Plaintiff’s reliance on HRS § 91-14 is

misplaced as HRS § 91-14 applies to an appeal of a contested

case, and has no application to election contests.

Based on the foregoing, the complaint’s claims made under

HRS §§ 11-173.5, 1 11-174.5, and 91-14 are dismissed for failure

to state a claim.

1 For a primary election contest, HRS § 11-173.5(b) requires the disposition be entered by “the fourth day after the return[.]” To fall under this deadline, the complaint must challenge the primary election results. See HRS § 11-173.5(b) (requiring the judgment to decide what candidate was nominated/elected). Accordingly, we find that the disposition deadline stated in HRS § 11-173.5(b) has no application because, as detailed in the complaint and Defendants’ motion to dismiss, no election results have posted.

3 *** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

B. Plaintiff’s claims under HRS § 11-172 are dismissed

Plaintiff’s complaint also challenged all primary election

ballots statewide under HRS § 11-172. In opposition, citing to

HRS § 11-172 and Tax Found. of Hawaiʻi v. State, 144 Hawaiʻi 175,

439 P.3d 127 (2019), Defendants argued that Plaintiff, as a

nonpartisan candidate for the Mayor’s race in the City and

County of Honolulu, has no standing to challenge all statewide

ballots, and only has standing to bring an election contest in

the race where he is a candidate.

The question presented is thus whether a nonpartisan

candidate for a county race has standing under HRS § 11-172

to challenge all primary ballots statewide.

In Hawaiʻi state courts, standing is solely an issue of

justiciability, arising out of prudential concerns of judicial

self-governance, and is based on concern about the properly

limited role of courts in a democratic society. See Tax Found.,

144 Hawaiʻi at 190-92, 439 P.3d at 142-44.

The rules of statutory interpretation require us to apply a

plain language analysis when statutory language is clear. See

Barker v. Young, 153 Hawaiʻi 144, 149, 528 P.3d 217, 222 (2023).

HRS § 11-172 provides:

§ 11-172. Contest for cause; generally

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
557 P.3d 831, 155 Haw. 102, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dicks-v-state-haw-2024.