JK v. HK

CourtHawaii Supreme Court
DecidedMay 18, 2026
DocketSCAP-24-0000673
StatusPublished

This text of JK v. HK (JK v. HK) 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
JK v. HK, (haw 2026).

Opinion

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

Electronically Filed Supreme Court SCAP-XX-XXXXXXX 18-MAY-2026 10:37 AM Dkt. 22 OP

IN THE SUPREME COURT OF THE STATE OF HAWAIʻI

---o0o--- ________________________________________________________________

JK, Appellant,

vs.

HK; NS; and CHILD SUPPORT ENFORCEMENT AGENCY, STATE OF HAWAIʻI, Appellees. ________________________________________________________________

SCAP-XX-XXXXXXX

APPEAL FROM THE FAMILY COURT OF THE FIRST CIRCUIT (CASE NO. 1FPA-XX-XXXXXXX)

May 18, 2026

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

OPINION OF THE COURT BY McKENNA, J.

I. Introduction

This transfer case arises from a May 20, 2024 amended

parentage petition, in which the Family Court of the First

Circuit (“family court”) 1 concluded in its November 20, 2024

1 The Honorable Jessi L.K. Hall presided.

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findings of fact (“FOFs”) and conclusions of law (“COLs”) that

an unmarried woman without a biological connection to the child

could not be a legal parent as a matter of law.

JK (pseudonym “Ava”) and HK (pseudonym “Bailey”), both

women, were in a long-term relationship and had a child together

(pseudonym “Kai”). After Ava and Bailey separated, Bailey began

restricting Ava’s visitation with Kai. Ava then filed this

petition to establish legal parentage over Kai based on Hawai‘i

Revised Statutes (“HRS”) § 584-4(a)(4) (2018), (the “holding out

presumption”) of paternity:

HRS § 584-4 Presumption of paternity. (a) A man is presumed to be the natural father of a child if:

. . . .

(4) While the child is under the age of majority, he receives the child into his home and openly holds out the child as his natural child[.]

Although, on its face, HRS § 584-4(a) applies only to a

male parent, in LC v. MG & Child Support Enf’t Agency, 143

Hawai‘i 302, 430 P.3d 400 (2018), this court discussed the

interplay between the paternity presumptions of HRS § 584-4

(2018) and the gender neutrality provision of HRS § 584-21

(2018). 143 Hawaiʻi at 312, 430 P.3d at 410. This court noted

that despite the gender-specific language of HRS § 584-4, HRS §

584-21 requires that in actions “‘to determine the existence or

nonexistence of a mother and child relationship[, i]nsofar as

practicable, the provisions of the [Uniform Parentage Act

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(“UPA”), HRS Chapter 584] applicable to the father and child

relationship shall apply.’” Id. (cleaned up). Hence, this

court held that “despite the gender-specific language [of the

paternity presumptions] in HRS § 584-4(a), the presumptions of

paternity equally apply in determining the existence or

nonexistence of a mother-child relationship.” Id.

The family court concluded LC did not apply here because LC

involved the application of gender-neutral language required by

the Marriage Equality Act (“MEA”) 2 -- but Ava and Bailey had

never been married and thus the MEA did not apply. Although the

family court found that Ava had held herself out as Kai’s

parent, it concluded that, as a matter of law, Ava could not

establish parentage through the holding out presumption.

We hold that the language and intent of the 1973 UPA, which

governed at the time of the family court’s ruling, 3 allowed a

mother and child relationship to be established through the same

methods applicable to the father and child relationship “insofar

2 The MEA, HRS § 572-1.8 (2018), provides as follows:

Interpretation of terminology to be gender-neutral. When necessary to implement the rights, benefits, protections, and responsibilities of spouses under the laws of this State, all gender-specific terminology, such as “husband”, “wife”, “widow”, “widower”, or similar terms, shall be construed in a gender-neutral manner. This interpretation shall apply to all sources of law, including statutes, administrative rules, court decisions, common law, or any other source of law.

3 The 1973 version of the UPA has been repealed by the 2017 version of the UPA in the new HRS Chapter 584A, effective January 1, 2026. See S.B. 1231, 33rd Leg., Reg. Sess. (2025).

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as practicable.” Just as it was practicable in LC to apply the

marital presumption, it is practicable in Ava’s situation to

apply the holding out presumption. As the family court found

that Ava brought Kai into her home and held Kai out as her own,

she is presumed to be Kai’s parent; furthermore, this

presumption of parentage was not rebutted by clear and

convincing evidence.

Hence, the family court erred by concluding Ava could not

establish parentage as a matter of law. Accordingly, we vacate

in part the family court’s FOFs and COLs and remand to the

family court for proceedings consistent with this opinion,

establishing legal parentage for Ava and addressing Ava’s

custody and visitation requests.

II. Background

A. Factual background

Bailey and Ava, both women, were in a romantic relationship

for more than twelve years. In 2021, they began planning to

start a family, with Bailey agreeing to carry the child. They

asked Ava’s cousin (pseudonym “Connor”), to be their sperm

donor, so that the child would be biologically connected to Ava.

Connor understood that both Bailey and Ava would be the child’s

parents and that he was not to be a parent.

On December 13, 2022, Kai was born. Ava was present with

Bailey at Kai’s birth and was the first person to hold Kai.

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Bailey and Ava chose Kai’s name together, including a hyphenated

last name containing both of their surnames. Ava was not listed

on Kai’s birth certificate and never formally adopted Kai. 4

After Kai’s birth, Ava, Bailey, and Kai lived together “as

a family” in a townhome on O‘ahu. Bailey was a stay-at-home

mother and Ava worked to support the family. They taught Kai to

call Ava “Dada.” During this time, Bailey and Ava shared

parenting responsibilities, such as changing diapers, waking up

for nighttime feedings, and “doing tummy time.” Ava was also

listed as Kai’s second parent with the pediatrician, was

authorized to take Kai to medical appointments, and participated

in decisions regarding Kai’s medical care.

In October 2023, Bailey and Ava separated. After their

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Cite This Page — Counsel Stack

Bluebook (online)
JK v. HK, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jk-v-hk-haw-2026.