Statute Annotations › Hawaii › Haw. Rev. Stat. § 603-21.5

Haw. Rev. Stat. § 603-21.5

Jurisdiction of circuit courts: the cases that interpreted this section

Jurisdiction
Hawaii
Case notes
27
Cited in passing
24
Citing cases indexed
57
Case dates
1974–2026
Screened through
2026-06-24
Checked for later law changes
2026-10-23
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

51 citing cases reviewed of 57 in the citation index: 27 interpreted the section (annotated below), 24 cited it only in passing. Cases filed after 2026-06-24 may not have been reviewed yet.

Have a situation under Haw. Rev. Stat. § 603-21.5?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Later changes in law

Changes after the earliest notes below. A note stating a rule one of these changed is marked "Law changed since".

  • 1998-04-29 Act 64 added subsection (b), giving circuit courts concurrent jurisdiction with family courts over specified family court offenses when charged with another qualifying offense. Source
  • 2004-04-23 Act 18 added violations of § 711-1106.4 to the matters within circuit and family courts' concurrent jurisdiction under subsection (b). Source
  • 2005-01-01 Act 161 of 2004 added guardianships and related proceedings concerning incapacitated adults under chapter 560, article V, to subsection (b)'s concurrent jurisdiction. Source
  • 2008-05-23 Act 107 added subsection (a)(4), giving circuit courts jurisdiction over actions to impeach county officers subject to impeachment. Source
  • 2017-07-11 Act 188 expanded subsection (b)(2)'s concurrent jurisdiction to cover mixed felony charges that also include a violation of §§ 709-903.5, 709-904, or 709-905. Source
  • 2026-08-26 State v. Amasiu clarified that § 571-14(a)(1) gives family court exclusive authority to try an offense against a child by the child's parent unless § 603-21.5(b)'s conditions for concurrent trial jurisdiction are met; circuit court nonetheless has authority under § 603-21.5(a)(1) and chapter 806 to receive a felony information and determine probable cause. Source

Circuit court jurisdiction over criminal offenses

Section 603-21.5 gives circuit courts jurisdiction over all state criminal offenses unless another law expressly provides otherwise, and that jurisdiction continues after a defendant demands a jury trial and later withdraws a not-guilty plea when no clear remand rule applies.

State v. Villados · filed 1974-03-27

HRS § 603-21.5 confers upon the circuit courts jurisdiction of all “criminal offenses cognizable under the laws of the State,” except for those offenses “otherwise expressly provided.” ... Applying this principle to the instant case, we find that where the statutes do not clearly mandate remand to the district court, the withdrawal of the plea of not guilty to a misdemeanor charge subsequent to an initial plea of not guilty and a demand for jury trial does not divest the circuit court of its continuing jurisdiction of the case. Thus the circuit court properly accepted the plea of nolo contendere and imposed sentence in this case.
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Section 603-21.5 gives circuit courts subject-matter jurisdiction over civil actions and proceedings unless the State Constitution or another statute precludes jurisdiction.

Sherman v. Sawyer · filed 1980-12-26(3)

HRS § 603-21.5 gives the circuit court subject matter jurisdiction over civil actions and proceedings. Thus, the circuit court has jurisdiction over all civil causes of action unless precluded by the State Constitution or by statute.
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Section 603-21.5(3) gives circuit courts broad jurisdiction over civil actions and proceedings, including a quiet-title claim joined with a determination and declaration of heirs, unless precluded by the Constitution or statute.

In Re the Determination & Declaration of the Heirs of Keamo · filed 1982-09-14(3)

HRS § 669-1 (c) confers on the circuit court jurisdiction over a quiet title action, the venue being in the circuit in which the property is located. An action to quiet title is a § 603-21.5 civil action or proceeding. We hold that under the broad statutory language of § 603-21.5, the court below had jurisdiction to adjudicate both a § 603-21.7(a)(1) determination and declaration of heirs matter and a § 669-1 quiet title claim.
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Section 603-21.5 gives Hawaii circuit courts jurisdiction over civil actions and proceedings, allowing them to decide whether a Motor Vehicle Industry Licensing Act provision is facially unconstitutional.

HOH Corp. v. Motor Vehicle Industry Licensing Board · filed 1987-05-11

And the several circuit courts of the State have power to decide whether a provision of the Motor Vehicle Industry Licensing Act, on its face, is unconstitutional. For they “have jurisdiction, except as otherwise expressly provided by statute, of: ... [c]ivil actions and proceedings.” HRS § 603-21.5.
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Section 603-21.5 gives circuit judges the criminal-offense jurisdiction underlying their authority to issue pen-register warrants under § 603-21.9(6).

State v. Rothman · filed 1989-08-10

The language of HRS § 603-21.9(6) is certainly broad enough to authorize circuit judges, in the exercise of the power over criminal offenses, given them under HRS § 603-21.5, to issue search warrants for the installation of such devices and the obtaining of such information. ... We agree, therefore, that under the statutes a circuit judge, and only a circuit judge, had the power to issue the warrant in question. Accordingly, since the warrant and the extensions thereof were signed by a district judge, they were invalid.
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Section 603-21.5(1) gives the circuit court jurisdiction over all DUI cases because DUI is a criminal offense.

State v. Dwyer · filed 1995-05-09(1)

In Lau, we held that DUI is a criminal offense and not a traffic offense. Therefore, the plain language of HRS § 603-21.5, coupled with our holding in Lau, clearly establishes that HRS § 603-21.5 confers jurisdiction upon the circuit court over all DUI cases.
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Section 603-21.5 gives circuit courts jurisdiction over civil actions and proceedings unless the State Constitution or another statute expressly precludes it.

State Ex Rel. Bronster v. Yoshina · filed 1997-01-28

Under HRS section 603-21.5, the circuit courts have jurisdiction “over all civil causes of action unless precluded by the State Constitution or by statute.” Sherman v. Sawyer, 63 Haw. 55, 58, 621 P.2d 346, 349 (1980). Clearly, the trial court had jurisdiction under this statute to consider the attorney general’s request for a declaratory judgment and related injunctions. We hold that the circuit court had jurisdiction in this action.
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Section 603-21.5 gives the circuit courts jurisdiction over civil actions and proceedings unless another statute expressly provides otherwise.

Frank v. Hawaii Planing Mill Foundation · filed 1998-07-02(3)

In this case, Frank’s complaint alleged a common-law tort action and nothing else. Nowhere in the complaint was there any mention of a claim for workers’ compensation benefits or any other claim over which the circuit court could not properly assume original jurisdiction. Because HRS § 603-21.5 grants jurisdiction to the “several circuit courts” over “civil actions and proceedings” unless “otherwise expressly provided by statute[,]” the circuit court properly assumed subject matter jurisdiction over Frank’s case.
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Section 603-21.5(3) gives circuit courts jurisdiction over civil actions and proceedings unless another statute expressly provides otherwise.

State v. Medeiros · filed 1999-01-11(3)

HRS § 603-21.5 provides in relevant part that "[t]he several circuit courts shall have jurisdiction, except as otherwise expressly provided by statute, of: ... (3) Civil actions and proceedings [.]" ... In short, it appears that the legislature has accorded the circuit courts the power to issue whatever orders are "necessary" to "carry into full effect the[ir] powers” and for the "promotion" or "furtherance” of justice, unless specifically prohibited by statute. ... Accordingly, despite the fact that Medeiros's motion was brought incident to his criminal conviction, the circuit court had subject matter jurisdiction over his motion for an injunction.
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Section 603-21.5 supplies the circuit court's jurisdiction over the criminal prosecution, making any defect in the family court's jurisdiction immaterial when a circuit court judge presides.

State v. Pedro. · filed 2021-06-04

The Circuit Court of the Second Circuit had jurisdiction under HRS § 603-21.5, and family courts are “divisions of the circuit courts of the State . . . ” HRS § 571-3.
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Section 603-21.5 gives Hawaiʻi circuit courts subject-matter jurisdiction over civil actions and proceedings.

Nakaoka v. Shizuru. · filed 2022-09-01

Here, given that HRS § 603-21.5 grants the circuit courts subject matter jurisdiction over civil actions and proceedings, and HRS § 508D-18 does not state that mediation is a jurisdictional prerequisite to filing suit, we conclude that the failure to mediate in these circumstances did not divest the Circuit Court of subject matter jurisdiction.
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Section 603-21.5(a)(1) gives circuit courts jurisdiction over criminal offenses cognizable under state law that were committed in the circuit or transferred there by change of venue.

State v. Obrero. · filed 2022-09-08(a)(1)

And under HRS § 603-21.5(a)(1), the circuit courts have jurisdiction over “[c]riminal offenses cognizable under the laws of the State, committed within their respective circuits or transferred to them for trial by change of venue from some other circuit court.” ... By charging Obrero with committing “[c]riminal offenses cognizable under the laws of the State, committed within [the First Circuit],” the complaint satisfied HRS § 603-21.5(a)(1)’s requirements for invoking the Circuit Court of the First Circuit’s subject-matter jurisdiction.
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Section 603-21.5(a)(1) gives the circuit court jurisdiction over cognizable criminal offenses committed within its circuit, and a complaint committed from the district court can satisfy that requirement without being refiled.

State v. Bautista · filed 2023-02-28(a)(1)

Because the complaint charged Bautista with cognizable offenses within the second circuit, the requirements of HRS § 603-21.5(a)(1) were satisfied.
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Subsection (a)(3) gives the circuit courts general jurisdiction over civil cases.

Hawaiian Ranchos Road Maintenance Corporation v. Halvorsen · filed 2026-06-24(a)(3)

The circuit courts have general jurisdiction over civil cases. HRS § 603-21.5(a)(3) (2016). The circuit court had jurisdiction over the subject matter of Corporation's amended complaint.
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Section 603-21.5(a) gives Hawaiʻi circuit courts jurisdiction over criminal offenses cognizable under state law.

Guity v. State of Hawaii · filed 2022-01-11(a)

As a former judge for the State of Hawai`i, First Circuit Court, Judge Ahn had general jurisdiction over criminal proceedings.3 See Haw. Rev. Stat. § 603-21.5(a) (“The several circuit courts shall have jurisdiction . . . of: (1) Criminal offenses cognizable under the laws of the State . . . .”). Judge Ahn therefore “did not act in the clear absence of all jurisdiction.” See Sakuma, 2009 WL 89119, at *3.
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General jurisdiction of circuit courts

Section 603-21.5 provides the circuit courts' general jurisdiction and, together with section 632-1, supplies the jurisdictional basis for declaratory-relief actions.

Citizens for the Protection of the North Kohala Coastline Ex Rel. Withington v. County of Hawai'i · filed 1999-07-13

Citizens instead relies on substantive statutes such as HRS §§ 46-1 (1993), 205-1 (1993), 343-1 (1993) and 92-12(b) (1993), which do not confer subject matter jurisdiction on the circuit court. Regardless of the erroneous recitation by Citizens’ attorneys, it is clear that the relief being sought was based on HRS §§ 603-21.5 (1993) (general jurisdiction of the circuit courts) and 632-1 (1993) (declaratory judgments). Thus, the circuit court properly accepted jurisdiction.
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Circuit court jurisdiction—civil actions and proceedings

Section 603-21.5 gives circuit courts jurisdiction over civil actions unless a statute expressly provides otherwise; an entity’s lack of attorney representation does not remove that jurisdiction.

Alexander & Baldwin , LLC v. Armitage. · filed 2022-04-05

Preliminarily, we reject the view of some jurisdictions that the absence of an attorney, where required, is jurisdictional. ... HRS § 603-21.5 (Supp. 2017) provides that the “circuit courts shall have jurisdiction, except as otherwise expressly provided by statute, of . . . [c]ivil actions and proceedings.”
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Section 603-21.5(a)(3) gives the circuit courts an independent subject-matter jurisdictional basis over civil actions and proceedings, including the County's declaratory-relief action.

County of Kaua'i Ex Rel. Nakazawa v. Baptiste · filed 2007-08-07(a)(3)

However, as indicated above, the County’s first amended complaint asserted jurisdiction pursuant to HRS § 603-21.5, quoted supra note 4, which provides the “independent jurisdictional basis” required by Kaluna. See State ex rel. Bronster v. Yoshina, 84 Hawai'i 179, 184, 932 P.2d 316, 321 (1997) (stating that the circuit court had jurisdiction pursuant to HRS § 603-21.5 to consider attorney general’s request for declaratory relief brought pursuant to HRS § 603-23). We, therefore, hold that the circuit court had subject matter jurisdiction over this case.
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Section 603-21.5(a) gives the circuit court jurisdiction over civil actions, including civil claims seeking $1 million in damages for theft, defamation, identity theft, fraud, and medical tort.

NASH-GIVENS v. Richardson · filed 2008-04-08(a)

Here, Appellant sought damages amounting to $1 million for alleged theft by Appellee, as well as for defamation, identity theft, fraud, and medical tort, civil claims which fall within the jurisdiction of the circuit court. HRS § 603-21.5(a). We conclude, therefore, that the circuit court erred in holding, as a matter of law, that it lacked subject-matter jurisdiction over Appellant's case.
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Section 603-21.5(3) gives the circuit court jurisdiction over civil actions and proceedings unless a statute precludes that jurisdiction.

Haines v. Haines · filed 2009-01-22(3)

Accordingly, the circuit court, which has jurisdiction over civil actions and proceedings unless precluded by statute, has jurisdiction over the complaint. HRS § 603-21.5(3) (Supp. 2007) .
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Section 603-21.5 gives circuit courts jurisdiction over civil actions and proceedings unless the Constitution or a statute expressly precludes it.

Alohacare v. Department of Human Services, State of Hawaii. · filed 2012-05-11

HRS § 603-21.5 (Supp.2005) provides in pertinent part that the several circuit courts shall have jurisdiction, ‘except as otherwise expressly provided by statute,’ of ‘[e]ivil actions and proceedings[.]’ According to Sherman, ‘the circuit court has jurisdiction over all civil causes of action unless precluded by the State Constitution or by statute.’ 63 Haw. at 58, 621 P.2d at 349. Thus, the courts have subject matter jurisdiction over ‘civil actions and proceedings^]’ and it is presumed that the courts have jurisdiction, unless the legislature, ‘expresslyU’ provides otherwise by statute. HRS § 603-21.5.
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Section 603-21.5 gives circuit courts jurisdiction over civil actions and proceedings unless another statute expressly provides otherwise.

Alaka'i Na Keiki, Inc. v. Matayoshi · filed 2012-05-11

According to Sherman, “the circuit court has jurisdiction over all civil causes of action unless precluded by the State Constitution or by statute.” 63 Haw. at 58, 621 P.2d at 349. Thus, the courts have subject matter jurisdiction over “civil actions and proceedings[,]” and it is presumed that the courts have jurisdiction, unless the legislature “expressly” provides otherwise by statute. HRS § 603-21.5.
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Section 603-21.5(a)(3) vests Hawaiʻi circuit courts with general jurisdiction over civil actions and proceedings.

In re: Application of Natalie Au Nishida · filed 2021-11-22(a)(3)

“[B]y statute, the state legislature has vested the circuit courts with general jurisdiction over 'civil actions and proceedings,' and specific jurisdiction over mortgage foreclosure actions.” First Hawaiian Bank v. Timothy, 96 Hawai#i 348, 356, 31 P.3d 205, 213 (App. 2001) (original brackets and citation omitted); see HRS § 603-21.5(a)(3) (Supp. 2013) (civil actions and proceedings); HRS chapter 667, part IA (1993 & Supp. 2013) (judicial foreclosure actions). ... Here, the Circuit Court had subject matter jurisdiction over the Foreclosure Case and personal jurisdiction over the successful bidder at the foreclosure sale.
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Section 603-21.5(a)(3) gives the circuit court jurisdiction over civil actions, including a civil claim for declaratory relief.

Cordery v. Ige · filed 2023-02-22(a)(3)

Rather, the jurisdiction to consider the merits of a claim for declaratory relief is with the circuit court. See HRS § 632-1(b) (providing relief by declaratory judgment “may be granted in civil cases”); HRS § 603-21.5(a)(3) (2016 & Supp. 2021) (establishing the circuit court with jurisdiction of civil actions).
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Section 603-21.5 gives Hawai'i circuit courts jurisdiction over civil actions unless the state constitution or another statute precludes it.

County of Hawai'i v. C & J Coupe Family Ltd. Partnership · filed 2008-12-24(a)(3)

Relying on HRS § 603-21.5, this court has declared that “the circuit court has jurisdiction over all civil causes of action unless precluded by the [sjtate [cjonstitution or by statute.” Sherman v. Sawyer, 63 Haw. 55, 58, 621 P.2d 346, 349 (1980) (emphasis added). ... It is concluded that, as a general rule, the court has subject matter jurisdiction over eminent domain proceedings.
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Concurrent jurisdiction over offenses against children

Law changed since The Hawaii Supreme Court in State v. Amasiu (Aug. 26, 2026) rejected this broader concurrent-jurisdiction rationale: family court has exclusive authority to try a single offense against a child by the child's parent, while circuit court may receive the felony information and determine probable cause; subsection (b) permits concurrent trial jurisdiction only when its stated conditions are met.

Section 603-21.5(b) permits circuit-court jurisdiction concurrent with the family court over an offense against a child by the child's parent, so filing the information in circuit court did not create a material jurisdictional defect for tolling the limitations period.

State v. Amasiu · filed 2024-11-15(b)

HRS § 603-21.5(b) governs when the circuit court has concurrent jurisdiction with the family court. ... Here, the First Felony Information was filed in the circuit court. About a month later, the Second Felony Information was filed in family court and the First Felony Information was dismissed. Because the family courts are divisions of the circuit court, any potential jurisdictional defect in filing the First Felony Information in circuit court for purposes of tolling the statute of limitations was immaterial. See State v. Pedro, 149 Hawaiʻi 256, 263 n.2, 488 P.3d 1235, 1242 n.2 (2021) (explaining "[a]ny potential jurisdictional defect [was] immaterial" because the circuit court "had jurisdiction under HRS § 603-21.5, and family courts are divisions of the circuit courts of the State") (citation and internal quotation marks omitted).
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Circuit court jurisdiction — equitable estoppel

Section 603-21.5(a)(3) gives the circuit court subject matter jurisdiction over an equitable estoppel claim.

Tran v. Department of Planning For the County of Maui · filed 2025-03-20(a)(3)

The circuit court had subject matter jurisdiction over the equitable estoppel claim under HRS § 603-21.5(a)(3) (2016).
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24 more cases cited this section only in passing

These cases mention the section without interpreting it (a string cite, a footnote, background). Listed so you can see the full citation record, not just the annotated rulings.

State v. Aiu, the opinion does not cite or construe Haw. Rev. Stat. § 603-21.5. Its statutory holdings concern HRS §§ 701-109 and 701-111, so it provides no holding about the target statute. opinion →
State v. Carroll, the court cites § 603-21.5(1) only as supporting authority for the proposition that both offenses were within one court's jurisdiction. It does not interpret the statute, explain its requirements, or decide its application. opinion →
Kona Old Hawaiian Trails Group Ex Rel. Serrano v. Lyman, the opinion only mentions § 603-21.5 in a footnote listing the current circuit-court jurisdiction provisions; it does not interpret or apply § 603-21.5. The court's jurisdictional analysis instead addresses HRS §§ 91-14 and 205A-6. opinion →
Tobosa v. Owens, the court cites § 603-21.5 only as general jurisdictional background while deciding whether the separate medical-malpractice prerequisites in HRS §§ 671-12 and 671-16 were satisfied; it does not construe or apply § 603-21.5 itself. opinion →
Matter of Herbert M. Dowsett Trust, the statute appears only in a string cite supporting the general statement that the same court enforces legal and equitable obligations. The court does not interpret, apply, or decide anything about HRS § 603-21.5. opinion →
State v. Okuda, the court cited HRS § 603-21.5(2) only as supporting authority for the circuit court's power to impose the penalty mandated by HRS § 286-138(a); it did not interpret or independently apply § 603-21.5(2). opinion →
Brooks v. Minn, the statute appears only in the trial court's quoted conclusion of law, which is procedural history. The appellate court did not construe § 603-21.5; its own holding that the circuit court had jurisdiction rested on the decree-judgment rule adopted from Caro. opinion →
Nishitani v. Baker, the court merely recited § 603-21.5 in footnote 11 as a general jurisdictional provision. Its holding rested on defendants’ failure to establish immunity and the rejection of their political-question argument, not on interpreting or applying this statute. opinion →
Ko'olau Agricultural Co. v. Commission on Water Resource Management, the statute appears only in the plaintiff's complaint as an allegation of subject-matter jurisdiction. The court did not construe or apply HRS § 603-21.5; its jurisdictional analysis addressed HRS §§ 632-1, 174C-7, and 174C-46. opinion →
GGS (HI), Inc. v. New York Diamond, Inc., Incidental: § 603-21.5(3) appears only in a see-also citation supporting the general proposition that circuit courts have jurisdiction over matters concerning registered property; the court does not construe or apply subsection (3). opinion →
Watland v. Lingle, the statute is mentioned only while reporting the jurisdictional holding in Bronster, a prior case; Watland v. Lingle does not interpret, apply, or decide anything about HRS § 603-21.5 itself. opinion →
Kalima v. State, the opinion merely reports the circuit court's jurisdictional conclusions, including its citation to HRS § 603-21.5; it does not itself decide what the statute means or how it applies. opinion →
Pono v. Molokai Ranch, Ltd., the opinion mentions § 603-21.5 as a jurisdictional provision quoted from the 1993 statute and as one of the provisions plaintiffs invoked to assert circuit-court jurisdiction, but it does not construe the statute or decide what jurisdiction it confers; the discussion expressly notes that the cited courts did not analyze that question. opinion →
HANA KOALI MESA LLC v. Kupau, the opinion only reports that the circuit court relied on HRS § 603-21.5(a)(3) for jurisdiction and affirms that ruling; it does not interpret or independently decide what the statute means or requires. opinion →
State v. Walker, the court cites HRS § 603-21.5(1) only as support for the general proposition that alleging a cognizable criminal offense is jurisdictional; it does not interpret or apply the statute’s jurisdictional grant. opinion →
Kanahele v. Maui County Council., the opinion mentions § 603-21.5 only in describing the petitioners' asserted jurisdictional basis and in an explanatory footnote; the court does not decide what the statute means, requires, covers, or how it applies. opinion →
Schwartz v. State., the court mentions § 603-21.5 only to describe the general statutory jurisdictional framework and compare it with the district-court provisions at issue; it does not construe or apply § 603-21.5 in deciding the case. opinion →
Alii Security Systems, Inc. v. Professional Security Consultants, Haw. Rev. Stat. § 603-21.5 is mentioned only in a footnote as a citation supporting a general proposition about circuit-court jurisdiction. The court did not construe, apply, or decide anything about the statute. opinion →
State v. Sardinha, the court cited § 603-21.5 parenthetically only to note the parties' undisputed agreement that the offenses were within circuit-court jurisdiction. It did not construe the statute or decide its jurisdictional application. opinion →
State v. Milne. ICA mem. op., filed 06/26/2020., the court’s holding construed HRS § 571-14(b) and the family court’s jurisdiction. Section 603-21.5 was mentioned only to describe the reciprocal effect of Act 64 of 1998 and was not construed or applied to resolve an issue in this case. opinion →
Alpha Inc. v. Board of Water Supply. ICA Opinion, filed 12/29/2023 [ada], 153 Haw. 564. Motion for Reconsideration, filed 01/08/2024. ICA Order Denying Motion for Reconsideration, filed 01/31/2024 [ada]. Application for Writ of Certiorari, filed 04/19/2024. Application for Writ of Certiorari, filed 04/22/2024. ICA Order of Correction, filed 03/22/2024. ICA Amended Order of Correction, filed 04/25/2024 [ada]. S.Ct Order Accepting Applications for Writ of Certiorari, filed 05/30/2024 [ada]., the court cites HRS § 603-21.5 only as an analogy illustrating that monetary thresholds can define jurisdiction. It does not interpret, apply, or decide any issue under that statute; the holding concerns the jurisdictional nature and application of HRS § 103D-709(d). opinion →
State v. Ah Puck, the opinion cites § 603-21.5(a)(1) only as background support for the circuit court's general criminal jurisdiction while deciding whether HRS § 806-85(d) authorizes district court judges to perform probable-cause, bail, and warrant functions. It does not interpret or apply § 603-21.5. opinion →
Kaneshiro v. North American Co. for Life & Health Insurance, the opinion cites § 603-21.5 only in a footnote identifying the statutory source of Hawaii trial-court jurisdiction. It does not construe the statute or decide any issue about its meaning, requirements, coverage, or application. opinion →
Deutsche Bank National Trust Company v. Ma'ilei, the court resolved whether the writ could be reissued, while § 603-21.5 appears only as a supporting citation and the court did not interpret or apply the section's own rules. opinion →

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