Oquendo v. State of Hawai'i, Office of Elections

CourtHawaii Supreme Court
DecidedSeptember 6, 2022
DocketSCEC-22-0000513
StatusPublished

This text of Oquendo v. State of Hawai'i, Office of Elections (Oquendo v. State of Hawai'i, Office of Elections) 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
Oquendo v. State of Hawai'i, Office of Elections, (haw 2022).

Opinion

Electronically Filed Supreme Court SCEC-XX-XXXXXXX 06-SEP-2022 08:18 AM Dkt. 14 FFCL SCEC-XX-XXXXXXX

IN THE SUPREME COURT OF THE STATE OF HAWAI#I

CARLOTTA OQUENDO, Plaintiff,

vs.

STATE OF HAWAI#I, OFFICE OF ELECTIONS, Defendant.

ORIGINAL PROCEEDING

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

On August 25, 2022 Plaintiff Carlotta Oquendo, also

known as Cherie Kuualoha Oquendo (Oquendo), filed a letter which

we construe as an election complaint. On August 30, 2022

Defendant State of Hawai#i Office of Elections (Office of

Elections) filed a motion to dismiss. Upon consideration of the

complaint and motion to dismiss, and having heard this matter

without oral argument, we enter the following findings of fact,

conclusions of law, and judgment.

FINDINGS OF FACT

1. Oquendo was one of three Primary Election

Republican Party candidates in the House District 45 race.

2. The 2022 Primary Election was on August 13, 2022.

3. Following a mandatory recount, the election result

for this race was, as follows: Wilbur, Tiana 403 Oquendo, Cherie Kuualoha 395 Aldeguer, Maysana A. 347 Blank votes 165

4. The election result was later updated by a final

printout published on August 25, 2022, with the following result

that included the last ballots validated by the City Clerk for

the City and County of Honolulu:

Wilbur, Tiana (Wilbur) 411 Oquendo, Cherie Kuualoha 406 Aldeguer, Maysana A. 353 Blank votes 169 Over votes 1

5. On the same day, August 25, 2022, Oquendo filed a

complaint under Hawai#i Revised Statutes (HRS) § 11-172 (Supp.

2021), which requests the following relief:

(a) That an order be issued requiring a manual

recount of the 2022 Republican Party House District 45 Primary

Election race; and

(b) An order requiring certain requests be

granted “to restore public confidence and assurances regarding

the integrity of Hawaii elections and reduce vulnerability to

election and voter fraud” that include maintenance of the voter

rolls, voter education, certain ballot handling procedures, an

adequate elections budget, increased access to voting to increase

voter participation, and preserving all elections records from

the “2020 General Election” beyond the federally mandated twenty-

two month retention period to improve transparency and access to

public records.

2 6. Oquendo asserts a lack of transparency during the

mandatory recount process, lack of resolution on certain election

integrity inquiries, and the final ballot counts support the

requested relief.

7. With regard to Oquendo’s assertion that there was

a lack of transparency during the mandatory recount process,

Oquendo recounts observations and interactions with the Office of

Elections during the mandatory recount process, including the

lack of responses from the Office of Elections during the

mandatory recount process.

8. With regard to the concern about the lack of

resolution on certain election integrity inquiries, Oquendo

asserts there were many deficiencies concerning: (a) a Manual

Audit Certification that was raised regarding the 2020 General

Election; (b) cybersecurity threats from foreign and other non-

state threats to alter the election results to conform to their

interests; (c) maintenance of the voter registration rolls in

light of a “specific case of a registered voter” in the 2020

General Election; and (d) various aspects with elections by mail.

9. With regard to the assertion that a final ballot

count supports the requested relief, Oquendo asserts a manual

recount could alter the outcome because the difference between

Oquendo and Wilbur is only five votes. She also points to a

credit data file from the City and County of Honolulu Elections

Office that states there were 34,559 ballots received on August

14, 2022, that “could have met the deadline for receipt by 7

3 p.m., Aug[ust] 13, 2022,” if receipt of these 34,559 ballots were

recorded in Greenwich Mean Time (GMT) because Hawai#i standard

time is ten hours behind GMT.

10. The Office of Elections asserts that the complaint

should be dismissed with prejudice because it’s untimely and

fails to state a claim upon which relief may be granted.

CONCLUSIONS OF LAW

1. HRS § 11-173.5(a) (2009 & Supp. 2021) provides in

pertinent part that “a complaint for a contest for cause that

arises from a mandatory recount pursuant to section 11-158 shall

be filed no later than 4:30 p.m. on the third calendar day

following the public announcement of the results of the mandatory

recount pursuant to section 11-158(c).”

2. The mandatory recount in this race resulted in a

difference of eight votes between Wilbur and Oquendo.

3. However, Oquendo’s complaint clearly refers to a

five vote difference between Wilbur and Oquendo, which is the

result shown by the August 25, 2022 final printout.

4. As such, Oquendo’s complaint does not “arise[]

from a mandatory recount pursuant to [HRS] section 11-158[,]”

and, thus, the time limit in which to file a primary election

complaint from a mandatory recount does not apply to Oquendo’s

complaint. See HRS § 11-173.5(a).

5. Oquendo filed the complaint on August 25, 2022, or

before the August 26, 2022 deadline for other primary election

complaints. See HRS § 11-173.5(a) (requiring the complaint to be

4 filed no later than 4:30 p.m. on the thirteenth day after a

primary election).

6. Oquendo’s complaint is thus timely.
7. When reviewing a request to dismiss a complaint,

the court’s review “is based on the contents of the complaint,

the allegations of which [the court] accept[s] as true and

construe[s] in the light most favorable to the plaintiff.

Dismissal is improper unless it appears beyond doubt that the

plaintiff can prove no set of facts in support of his claim which

would entitle him to relief.” Casumpang v. ILWU, Local 142, 94

Hawai#i 330, 337, 13 P.3d 1235, 1242 (2000) (quotation marks and

citation omitted).

8. When considering a request to dismiss a complaint,

the court need not accept conclusory or formulaic recitations on

the legal effects of the events alleged. Kealoha v. Machado, 131

Hawai#i 62, 74, 315 P.3d 213, 225 (2013).

9. A complaint challenging the results of a primary

election fails to state a claim unless the plaintiff demonstrates

errors, mistakes, or irregularities that would change the outcome

of the election.

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Related

Funakoshi v. King
651 P.2d 912 (Hawaii Supreme Court, 1982)
Elkins v. Ariyoshi
527 P.2d 236 (Hawaii Supreme Court, 1974)
Casumpang v. ILWU, LOCAL 142
13 P.3d 1235 (Hawaii Supreme Court, 2000)
Kealoha v. Machado.
315 P.3d 213 (Hawaii Supreme Court, 2013)

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