In re: Guardianship of I.W

CourtHawaii Supreme Court
DecidedJune 16, 2026
DocketSCWC-23-0000356
StatusPublished

This text of In re: Guardianship of I.W (In re: Guardianship of I.W) 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
In re: Guardianship of I.W, (haw 2026).

Opinion

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Electronically Filed Supreme Court SCWC-XX-XXXXXXX 16-JUN-2026 09:10 AM Dkt. 23 OPA

IN THE SUPREME COURT OF THE STATE OF HAWAIʻI

---o0o---

IN THE MATTER OF THE GUARDIANSHIP OF I.W. AND T.E.

SCWC-XX-XXXXXXX

CERTIORARI TO THE INTERMEDIATE COURT OF APPEALS (CAAP-XX-XXXXXXX; CASE NOS. 5GD151000035 and 5GD151000036 (consolidated))

JUNE 16, 2026

DEVENS, C.J., McKENNA, EDDINS, AND GINOZA, JJ., AND CIRCUIT JUDGE MORIKONE, ASSIGNED BY REASON OF VACANCY

OPINION OF THE COURT BY EDDINS, J.

I.

The right of a parent to raise their child is a fundamental

liberty at the heart of our state’s constitutional tradition.

This case explores the status of that interest when a parent

consents to guardianship.

The right remains intact.

We hold two things. *** FOR PUBLICATION IN WEST’S HAWAIʻI REPORTS AND PACIFIC REPORTER ***

First, the rebuttable presumption that a fit parent acts in

the best interest of their child extends to guardianship

proceedings. Consenting to a guardian’s care is not a waiver.

The presumption endures despite that consent.

Second, before a family court may set that presumption

aside, the due process and privacy protections in article I,

sections 5 and 6 of the Hawaiʻi Constitution require clear and

convincing evidence of unfitness.

We affirm the Intermediate Court of Appeals (ICA) in

result. The ICA identified the correct standard. But we anchor

the standard in the Hawaiʻi Constitution.

Two further points. Clear and convincing evidence governs

fitness. The preponderance of the evidence standard governs the

best interest analysis under Hawaiʻi Revised Statutes (HRS)

§ 560:5-210(b) (2018) and HRS § 571-46 (2018). And the parental

presumption is not a conclusive rule that makes guardianship

terminable at will. It is a substantial, but rebuttable,

preference that must inform the family court’s assessment of the

child’s best interest.

We return the case to the family court for a fitness

determination under the correct standard.

II.

A. Factual Background

This is a contested guardianship over two children. Now

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teenagers, they have lived with their grandparents for nearly a

decade. The grandparents seek to keep and expand their role.

The mother wants to end it.

Toby and Izzy are the biological children of Mother and

Father. (Pseudonyms are used for the minors.) Mother and

Father were never married. They broke up when Mother was six

months pregnant with their second child, Izzy.

Toby is now sixteen. Izzy is thirteen.

Grandmother is Mother’s mother.

In January 2016, when Toby was five and Izzy was two,

Mother and Father consented to appoint Grandmother and her

husband, Grandfather, as unlimited co-guardians for them. The

guardianship petitions filed by Grandmother and Grandfather

(Guardians) stated that “Mother requests assignment of

guardianship to petitioners because of inability to care for the

[children] due to personal, emotional and financial issues.”

Mother testified that she was then unemployed, on food

stamps, without stable housing, and not “in the best

position . . . to meet [the children’s] needs and to care for

them.” She viewed the arrangement as temporary.

Over four years later, in March 2020, Mother and her

boyfriend filed petitions to terminate the children’s

guardianships.

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Within two months, Grandmother and Grandfather moved the

family court to relocate the children from Kauaʻi to Oregon,

citing Grandmother’s loss of work during the COVID-19 pandemic.

After mediation, the parties stipulated in July 2020 that

Grandfather would resign as co-guardian; Grandmother would

continue as a limited guardian; and the children would move to

Oregon and live with her during the school year, subject to

Mother’s custodial time during breaks. The guardianship

termination petitions went no further.

Since the move, Toby has been diagnosed with autism and

ADHD, and receives specialized school services. Both children

began receiving therapy in Kauaʻi, then continued services in

Oregon. Caring for the children’s emotional and special needs,

and Mother’s ability to manage that care, became a focal point

of the fitness dispute that followed.

In December 2021, Grandmother moved to undo the 2020

stipulation, reinstating Grandfather as co-guardian and

restoring the guardianship to unlimited.

Then, in February 2022, Mother and her boyfriend filed

joint petitions to terminate the guardianships for both

children. The boyfriend’s standing to participate in the family

court proceedings as an “interested party” was challenged in

circuit court, but Guardians later withdrew the motion. At the

ICA, Guardians unsuccessfully attempted to strike the

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boyfriend’s briefing. The Guardians have not renewed their

objections here, and we do not address them.

Father does not seek custody. He supports continuing the

guardianship.

1. Family Court Decision

The family court held four days of hearings on the

termination petition and motion to modify the guardianship.

In January 2023, the family court granted Grandmother’s

motion to undo the 2020 stipulation. It denied the petitions

for termination of the children’s guardianships.

The family court applied HRS § 560:5-210(b) to the

termination question. It invoked the parental presumption from

In re Guardianship of Jane Doe, subject to rebuttal. See In re

Guardianship of Doe, 93 Hawaiʻi 374, 385, 4 P.3d 508, 519 (App.

2000).

The court assessed Mother’s fitness under the preponderance

of the evidence standard. See In re Guardianship of Doe, 106

Hawaiʻi 75, 78, 101 P.3d 684, 687 (App. 2004) (applying a

preponderance of the evidence standard to fitness in

guardianship proceedings). It found her unfit. The court

grounded that determination on Mother’s “limited involvement

with her children and her demonstrated lack of knowledge or

ability to take into account [the children’s] emotional and

special needs.”

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The court found that Mother did not “demonstrate an

understanding of [Izzy’s] emotional needs nor [Toby’s] special

needs relating to his ADHD and [a]utism diagnos[e]s.” The

court-appointed guardian ad litem testified that Mother was

unable to parent the children. And Mother, the court found,

“made little to no attempt to show that it is in the children’s

best interest to have the guardianship terminated.” She relied

solely on the parental presumption. Because Mother was not fit,

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In re: Guardianship of I.W, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-guardianship-of-iw-haw-2026.