Rosenlee v. Takahashi

CourtHawaii Supreme Court
DecidedJanuary 10, 2025
DocketSCEC-24-0000800
StatusPublished

This text of Rosenlee v. Takahashi (Rosenlee v. Takahashi) 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
Rosenlee v. Takahashi, (haw 2025).

Opinion

Electronically Filed Supreme Court SCEC-XX-XXXXXXX 10-JAN-2025 02:13 PM Dkt. 47 FFCL

SCEC-XX-XXXXXXX

IN THE SUPREME COURT OF THE STATE OF HAWAIʻI ________________________________________________________________

COREY ROSENLEE, Plaintiff,

vs.

GLEN TAKAHASHI, in his official capacity as the City Clerk of the City and County of Honolulu; REX QUIDILLA, in his official capacity as the Elections Administrator of the City and County of Honolulu; SCOTT NAGO, Chief Election Officer, State of Hawaiʻi Office of Election; and ELIJAH PIERICK, Defendants. ________________________________________________________________

ORIGINAL PROCEEDING

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

Upon consideration of the “Complaint for Election Contest”

filed by the Plaintiff Corey Rosenlee on November 25, 2024

(complaint) and the parties’ submissions, we rule in favor of

Defendants and against Plaintiff as to all claims stated in the

complaint. In accordance with Hawaiʻi Revised Statutes (HRS) § 11-174.5

(Supp. 2021), we enter the following findings of fact,

conclusions of law and judgment.

FINDINGS OF FACT

1. As of 2020 the elections in the State of Hawaiʻi have

been conducted primarily by mail, but in-person voting is still

available at voter service centers. See HRS §§ 11-101 (Supp.

2021), 11-109 (Supp. 2021).

2. On November 5, 2024, the State of Hawaiʻi held a

general election for State Representative, District 39. The two

candidates were the Republican candidate, Defendant Elijah

Pierick, and the Democratic candidate, Plaintiff Corey Rosenlee.

3. For the subject election, the State of Hawaiʻi Office

of Elections was responsible for the printing and counting of

ballots. HRS § 11-110(b)(1)(B) (Supp. 2021). The City Clerk of

the City and County of Honolulu was responsible for the mailing

and receipt of ballots and voter service centers, among other

duties. HRS § 11-110(b)(1)(A); see HRS §§ 11-106 (Supp. 2021),

11-108 (Supp. 2021).

4. HRS § 11-102 (Supp. 2022) sets forth the procedures

for conducting elections by mail. Under this process, on or

about Friday, October 18, 2024, the Clerk began mailing out the

ballot packages to registered voters. See HRS § 11-102(b). The

ballot package to a voter included: an official ballot; a return

2 identification envelope with postage prepaid; a secrecy envelope

or secrecy sleeve; and instructions. HRS § 11-102(a).

5. For the general election, pursuant to HRS § 11-106,

Hawaiʻi Administrative Rule (HAR) § 3-177-651 (eff. 2020), and

HAR § 3-177-652 (eff. 2020), the Clerk was responsible for

reviewing return identification envelopes and providing notice

to voters whose envelopes were deemed deficient.

6. HRS § 11-106 provides:

§ 11-106. Deficient return identification envelopes

If: (1) A return identification envelope is returned with an unsigned affirmation;

(2) The affirmation signature does not match a reference signature image; or

(3) A return identification envelope contains another condition that would not allow the counting of the ballot,

the clerk shall make an attempt to notify the voter by first class mail, telephone, or electronic mail to inform the voter of the procedure to correct the deficiency. The voter shall have five business days after the date of the election to cure the deficiency. The chief election officer may adopt rules regarding requirements and procedures for correcting deficient return identification envelopes. The counting of ballots and disclosure of subsequent election results may continue during the time period permitted to cure a deficiency under this section. The clerk’s inability to contact voters under this section shall not be grounds for a contest for cause under section 11-172. This section shall apply to all return identification envelopes, including ballots utilizing the provisions of section 11-107 or chapter 15 or 15D.

7. HAR § 3-177-651 provides in pertinent part:

§ 3-177-651. Return identification envelopes; general preparing of ballots for counting.

(a) Upon receipt of the return identification envelope, the clerk may prepare the ballots for counting. Before opening return identification envelopes and counting the ballots,

3 the return identification envelopes shall be checked for the following:

(1) Signature on the affirmation statement;

(2) Whether the signature corresponds with a reference signature image using the provisions of HAR § 3-177-652; and

(3) Whether there is a condition that would not allow the counting of the contents of the return identification envelope (e.g. the voter has already voted, or otherwise returned a return identification envelope that has been validated).

(b) If any requirement listed in subsection (a) is not met or if the return identification envelope appears to be tampered with, the clerk shall mark across the face of the envelope “invalid” and it shall be kept in the custody of the clerk and disposed of as prescribed for ballots in HRS § 11-154, unless it is subsequently determined to be valid. To the extent a return identification envelope is deemed invalid, the provisions of HAR § 3-177-654 relating to the correction of deficient return identification envelopes may apply.

. . . .

(e) All return identification envelopes complying with subsection (a) shall be deemed valid and secured by election officials for subsequent processing and counting.

8. HAR § 3-177-652 provides:

§ 3-177-652. Return identification envelopes; signature validation.

(a) The clerk will initially compare the signature on a return identification envelope with the reference signature or reference signatures of the voter. The clerk may authorize the use of a signature device, as defined in HAR § 3-177-653, to compare signatures. A signature considered matched by a signature device will be considered valid and not require further verification.

(b) A “reference signature” is any signature provided in connection with the administration of elections or any signature provided to election officials from a governmental entity obtained in the ordinary course of business (e.g.

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

Related

Waters v. Nago
468 P.3d 60 (Hawaii Supreme Court, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Rosenlee v. Takahashi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rosenlee-v-takahashi-haw-2025.