Haw. Rev. Stat. § 657-7

Haw. Rev. Stat. § 657-7 provides a two-year statute of limitations for personal injury actions under Hawaii law.

Turner v. City and County of Honolulu · filed 2010-01-22

Haw. Rev. Stat. § 657-7 (providing two-year statute of limitations for personal injury actions under Hawaii law)

Haw. Rev. Stat. § 657-7 imposes a two-year statute of limitations for personal injury actions.

Hubbart v. State of Hawaii Office of Consumer Protection · filed 2010-01-22

Moreover, the district court properly dismissed all of the claims as barred by the statute of limitations under Hawaii law. See Haw. Rev. Stat. § 657-7 (2009) (two-year statute of limitations for personal injury actions)

Haw. Rev. Stat. § 657-7 provides a two-year statute of limitations for personal-injury claims and applies to the plaintiffs' Bivens claims.

Schulze v. Maglasang · filed 2010-04-19§ 657-7

The district court properly granted summary judgment for defendants on Ms. Schulze’s claims because they are time-barred and not subject to equitable tolling. See Haw. Rev. Stat. § 657-7 (two-year statute of limitations for personal injury claims)

Haw. Rev. Stat. § 657-7 imposes a two-year statute of limitations that bars the IIPEA claims at issue.

Lizza v. Deutsche Bank National Trust Co. · filed 2017-10-27

Hawaii’s two-year statute of limitations bars Dean’s and Mauch’s IIPEA claims.

Hawai‘i’s two-year statute of limitations for personal injury actions applies to claims brought under 42 U.S.C. § 1983.

Courtney Bird v. State of Hawaii · filed 2019-08-23

In Hawai‘i, the statute of limitations for personal injury actions is two years. See Haw. Rev. Stat. § 657-7.

Haw. Rev. Stat. § 657-7 sets a two-year limitations period for claims seeking damages for injury to persons or property, and a negligence claim accrues under the discovery rule when the plaintiff knew or should have known of the defendant’s negligence.

Mueller v. State of Hawaii Department of Public Safety · filed 2020-03-18

Haw. Rev. Stat. § 657-7 provides for a two-year statute of limitations for damages to persons or property. In a negligence action, the discovery rule applies, meaning the claim for relief does not accrue until the plaintiff knew or should have known of defendant’s negligence.

Haw. Rev. Stat. § 657-7 provides a two-year statute of limitations for personal injury actions, including the limitations period used for § 1983 claims in Hawaiʻi.

Puana v. Kealoha · filed 2021-06-04

The Hawai`i statute of limitations for personal injury actions is two years. Haw. Rev. Stat. § 657-7.

Haw. Rev. Stat. § 657-7 provides a two-year statute of limitations for personal injury actions.

Morelli v. Hyman · filed 2021-07-08§ 657-7

Haw. Rev. Stat. § 657-7 (two-year statute of limitations for personal injury actions)

Haw. Rev. Stat. § 657-7 sets a two-year statute of limitations for personal-injury actions in Hawaii.

Mueller v. State of Hawaii Department of Public Safety · filed 2021-07-20

In Hawaii, the statute of limitations for personal injury actions is two years. See Haw. Rev. Stat. § 657-7; Bird v. Dep't of Human Servs., 935 F.3d 738, 743 (9th Cir. 2019).

Haw. Rev. Stat. § 657-7 sets a two-year statute of limitations for personal-injury actions in Hawaii.

Malori v. Oahu Community Correctional Center (OCCC) · filed 2021-11-17

In Hawaii, the statute of limitations for personal injury actions is two years.

Haw. Rev. Stat. § 657-7 requires a tort plaintiff to file suit no later than two years after the claim accrues.

Fatai v. City and County Honolulu · filed 2022-01-03

the general torts statute requires a would-be plaintiff to initiate a suit no later than two years after a claim accrues.

Haw. Rev. Stat. § 657-7 provides a two-year statute of limitations for personal-injury actions, and that limitations period governs § 1983 claims in Hawaiʻi.

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

In Hawai`i, the statute of limitations for personal injury actions is two years. See Haw. Rev. Stat. § 657-7.

Haw. Rev. Stat. § 657-7 provides a two-year limitations period for personal-injury actions.

Puana v. Kealoha · filed 2022-02-28

The Hawai`i statute of limitations for personal injury actions is two years. Haw. Rev. Stat. § 657-7.

Haw. Rev. Stat. § 657-7 gives personal-injury actions a two-year limitations period, which applies to § 1983 claims.

Beckstrand v. Read · filed 2017-03-13§ 657-7

Hawaii’s two-year statute of limitations for personal injury actions applies to Beckstrand’s claims under 42 U.S.C. § 1983.

Haw. Rev. Stat. § 657-7’s two-year limitations period governs § 1983 personal-injury claims in Hawaii.

Chung v. City & County of Honolulu · filed 2018-06-27§ 657-7

Hawaii’s two-year statute of limitations for personal injuries governs Chung’s § 1983 claims.

Haw. Rev. Stat. § 657-7 provides a two-year limitations period for personal-injury actions, including § 1983 claims.

Scaperotta v. Kauai Police Dept. · filed 2021-01-27§ 657-7

In Hawaii, the statute of limitations for personal injury actions is two years.

Haw. Rev. Stat. § 657-7 provides a two-year limitations period for personal-injury actions, including § 1983 claims.

Scaperotta v. Kauai Police Dept. · filed 2021-03-16§ 657-7

In Hawaii, the statute of limitations for personal injury actions is two years.

Haw. Rev. Stat. § 657-7 requires actions for compensation for injury to persons or property to be filed within two years after the cause of action accrues, subject to the exception in § 657-13.

Dural v. City and County of Honolulu · filed 2023-02-17

Haw. Rev. Stat. § 657-7 provides that “[a]ctions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued, and not after, except as provided in section 657-13.”

Haw. Rev. Stat. § 657-7 provides a two-year limitations period for personal-injury actions in Hawaii, which governs § 1983 claims in the forum.

Coates v. Cluney · filed 2023-04-14

In general, the statute of limitations for personal injury actions in Hawaii is two years. See Haw. Rev. Stat. § 657-7; Bird v. Dep’t of Hum. Servs., 935 F.3d 738, 743 (9th Cir. 2019).

Haw. Rev. Stat. § 657-7 provides a two-year limitations period for personal injury actions in Hawaii, which governs § 1983 claims and generally governs Title II ADA claims when no longer federal limitations period applies.

Char v. Tresch · filed 2023-10-26

In general, the statute of limitations for personal injury actions in Hawaii is two years. See Haw. Rev. Stat. § 657-7; Bird v. Dep’t of Hum. Servs., 935 F.3d 738, 743 (9th Cir. 2019).

Haw. Rev. Stat. § 657-7 generally imposes a two-year statute of limitations on actions seeking compensation for personal injury or property damage, subject to the statutory exception in § 657-13.

Dural v. City and County of Honolulu · filed 2023-11-09

Haw. Rev. Stat. § 657-7 provides that “[a]ctions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued, and not after, except as provided in section 657-13.”

Haw. Rev. Stat. § 657-7 supplies a two-year limitations period for personal-injury actions, including claims brought under 42 U.S.C. § 1983.

Larry Wayne Lundy Jr Trust v. State of Hawaii · filed 2024-04-30§ 657-7

actions brought under § 1983 are subject to the forum state’s statute of limitations for personal injury actions, which in Hawai‘i is two years (citing Haw. Rev. Stat. § 657-7).

Haw. Rev. Stat. § 657-7 sets a two-year statute of limitations for personal-injury actions in Hawaii.

Nash v. Pacheco · filed 2024-05-13

In general, the statute of limitations for personal injury actions in Hawaii is two years. See Haw. Rev. Stat. § 657-7 (2016); Bird, 935 F.3d at 743.

Haw. Rev. Stat. § 657-7 provides a two-year statute of limitations for personal-injury actions in Hawaii.

Nakaahiki v. Kauai Police Department Officers · filed 2025-10-10

In general, the statute of limitations for personal injury actions in Hawaii is two years.

Haw. Rev. Stat. § 657-7 sets a two-year statute of limitations for personal injury actions in Hawaiʻi.

Anger · filed 2026-02-17

In Hawai`i, the statute of limitations for personal injury actions is two years.

Haw. Rev. Stat. § 657-7 requires actions for compensation for damage or injury to persons or property to be filed within two years after the cause of action accrues.

Manaole · filed 2026-04-30

In Hawai‘i, the statute of limitations is two years. Beckstrand v. Read, 680 Fed.Appx. 609, 610 (9th Cir. 2017) (citing Haw. Rev. Stat. § 657-7) (“Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued . . . .”).

Haw. Rev. Stat. § 657-7 requires actions seeking compensation for damage or injury to persons or property to be filed within two years after the cause of action accrues.

Manaole · filed 2026-05-15

“Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued . . . .”

Section 657-7 requires actions seeking compensation for damage or injury to persons or property to be filed within two years after the cause of action accrues.

Nakamura · filed 2026-06-25

“Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued . . . .”

Haw. Rev. Stat. § 657-7 imposes a two-year statute of limitations on IIED claims.

Puana v. Kealoha · filed 2023-01-31§ 657-7

Moreover, Plaintiffs’ IIED claim against Katherine has a two-year statute of limitations. See Haw. Rev. Stat. § 657-7; see also U.S. E.E.O.C. v. NCL Am., 535 F. Supp. 2d 1149, 1169 (D. Hawai`i 2006)

Haw. Rev. Stat. § 657-7 sets a two-year deadline for bringing personal-injury actions in Hawaii.

Nash v. Pacheco · filed 2024-04-08§ 657-7

In general, the statute of limitations for personal injury actions in Hawaii is two years. See Haw. Rev. Stat. § 657-7 (2016); Bird, 935 F.3d at 743.

Haw. Rev. Stat. § 657-7 provides a two-year general personal-injury limitations period that applies to § 1983 claims in Hawaiʻi.

Kulik v. State of Hawaii · filed 2024-08-08§ 657-7

the “‘general’ personal injury” limitation period in Haw. Rev. Stat. § 657-7 of two years applies to Section 1983 actions in Hawai`i).

Haw. Rev. Stat. § 657-7 imposes a two-year limitations period for personal-injury, negligence, and IIED claims, with accrual under the discovery rule when the plaintiff knew or should have known the necessary facts.

Shook v. County of Hawaii Police Department · filed 2022-08-31§ 657-7

Shook’s IIED claim and negligence claim are also subject to the § 657-7 two-year statute of limitations.

Haw. Rev. Stat. § 657-7 requires actions seeking compensation for injury to a person or property to be filed within two years after the cause of action accrues.

Mau v. City and County of Honolulu · filed 2025-04-04§ 657-7

In Hawaii, the statute of limitation for personal injury cases is two years.

Haw. Rev. Stat. § 657-7 provides a two-year limitations period that barred some of the plaintiffs’ state-law claims.

Abing v. Evers · filed 2023-05-12§ 657-7

Hawaii’s two-year statute of limitations bars some of Plaintiffs’ state law claims ... Plaintiffs’ 42 U.S.C. § 1986 claim was barred by a one-year statute of limitations.

Section 657-7 provides a two-year limitations period for personal-injury actions and governs § 1983 claims.

Adam v. Hawaii Property Insurance · filed 2007-08-22

However, the district court properly applied Haw.Rev.Stat. § 657-7, which is Hawaii’s two-year statute of limitations for personal injury actions. See Price v. State of Hawaii, 939 F.2d 702, 708 n. 7 (9th Cir.1991); see also Pele Defense Fund v. Paty, 73 Haw. 578, 837 P.2d 1247, 1259 (1992) (“We hold that the two-year statute of limitations set forth in HRS § 657-7 governs § 1983 actions.”).

Section 657-7 supplies Hawaii’s two-year general personal-injury limitations period, which applies to § 1983 claims when federal law provides no limitations period.

Wideman v. Ige · filed 2020-05-18

Because § 1983 does not contain its own statute of limitation, the Court applies Hawaii’s two-year statute of limitation for personal injury actions to Wideman’s federal claims. See Butler v. Nat’l Cmty. Renaissance of Cal., 766 F.3d 1191, 1198 (9th Cir. 2014) (holding federal courts apply the forum state’s statute of limitation and state laws for personal injury actions and tolling, to the extent they are consistent with federal law); see also Pele Defense Fund v. Paty, 73 Haw 578, 597-98 (1992) (discussing HRS § 657-7, Hawaii’s two-year “general personal injury” provision).

Section 657-7 provides a two-year statute of limitations for personal injury actions, and that period applies to Section 1983 claims.

Callender v. Department of the Prosecuting Attorney for the County of Maui · filed 2021-01-28

And under Hawai‘i law, the statute of limitations for personal injury actions, which applies to Section 1983 actions, is two years. Hawaiʻi Revised Statutes (“HRS”) § 657-7; see Pele Def. Fund v. Paty, 73 Haw. 578, 595, 837 P.2d 1247, 1259 (1992) (holding that the limitations period in HRS § 657-7 applies to Section 1983 actions). Accordingly, the statute of limitations for Plaintiffs’ Section 1983 claims is two years.

Section 657-7 provides a two-year statute of limitations for personal-injury actions, which governs § 1983 claims in Hawai‘i.

Abing v. Evers · filed 2021-12-21

Plaintiffs’ § 1983 claims are subject to Hawaii’s two-year statute of limitations for personal injury actions. See HRS § 657-7; Taylor v. Regents of the Univ. of Cal., 993 F.2d 710, 711–12 (9th Cir. 1993) (explaining that the state personal injury statute of limitations governs actions under 42 U.S.C. § 1983).

Section 657-7 imposes a two-year statute of limitations on personal-injury actions in Hawaiʻi.

Thunderfoot v. United States · filed 2023-08-22

“In Hawai’i, the statute of limitations for personal injury actions is two years.”

Section 657-7 requires actions seeking compensation for injury to persons or property to be filed within two years after accrual, and supplies the analogous limitations period for certain federal discrimination claims.

Greer v. Hawaii Permanente Medical Group, Inc. · filed 2025-01-31

In short, the court applies HRS § 657-7’s two-year statute of limitations to Greer’s ADA Title III claim.

Section 657-7 requires actions seeking compensation for damage or injury to persons or property to be filed within two years after accrual, but does not govern a wrongful-foreclosure claim alleging nonphysical injury to an intangible property interest; § 657-1(4) governs instead.

Guyer v. Nationstar Mortgage LLC · filed 2022-11-30

Here, as in Delapinia, Guyer did not allege any physical harm to the Property. Instead, Guyer claims Nationstar and Fannie Mae caused a nonphysical injury to his intangible interest by wrongfully "depriv[ing him] of his possession, record title, and use of the Property[.]" Thus, the six-year statute of limitations under HRS § 657-1(4) governs Guyer's claim for wrongful foreclosure.

Section 657-7 provides a two-year limitations period for personal-injury claims, including § 1983 claims.

Conklin v. Espinda · filed 2025-01-24

Hawaii’s two-year personal injury statute of limitations, Hawaii Revised Statutes (“HRS”) § 657-7, applies to § 1983 claims. See, e.g., Bird. v. Dep’t of Human Servs., 935 F.3d 738, 743 (9th Cir. 2019).

Section 657-7 provides a two-year limitations period for personal injury claims and applies to § 1983 claims.

Cabral · filed 2026-02-24

Hawaii’s two-year statute of limitations for personal injury claims, Hawaii Revised Statutes (“HRS”) § 657-7, applies to § 1983 claims.

Section 657-7 requires personal-injury actions to be filed within two years after accrual, and a claim accrues when the plaintiff discovers or reasonably should have discovered the act, injury, and causal connection.

Hogan v. Dow Chemical Co. · filed 1987-04-21

In Hawaii, an action for personal injuries must be brought within two years after the cause of action accrues. Haw. Rev.Stat. § 657-7. A claim accrues under this statute when the plaintiff discovers or reasonably should have discovered the complained of act, the injury and the causal connection between the two. Yamaguchi v. Queen’s Medical Center, 65 Haw. 84, 648 P.2d 689 (1982). The district court held that, insofar as the plaintiffs’ personal injury claims were concerned, the two-year statute started to run no later than 1979, and appellants concede that the Hawaiian statute, standing alone, would have barred their common-law, personal injury claims prior to the bringing of their suits in 1982.

Section 657-7 requires actions seeking compensation for damage or injury to persons or property to be filed within two years after the cause of action occurred.

C & W Construction Co. v. Brotherhood of Carpenters & Joiners, Local 745 · filed 1988-06-07

Haw.Rev.Stat. § 657-7 provides in pertinent part: “Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action occurred, and not after_” The emotional distress claims fall within the coverage of this statute. The plaintiffs filed their complaint more than two years after the final alleged tortious acts of the defendants. These claims are DISMISSED as time barred under Haw.Rev.Stat. § 657-7.

Section 657-7 requires tort actions to be instituted within two years after the cause of action accrues.

Heiser v. Association of Apartment Owners of Polo Beach Club · filed 1993-07-20

First, Plaintiffs have complied with the literal requirements of the Hawaii statute of limitations and rules of procedure. Plaintiffs filed a complaint with this Court within two years after their tort action accrued. This complies with Haw.Rev.Stat. § 657-7 and Haw.R.Civ.P. 3.

Section 657-7 sets a two-year limitations period for tort actions concerning damage to persons or property, running from accrual of the cause of action.

B.K.B., Plaintiff-Appellant-Cross-Appellee v. Maui Police Department, County of Maui, County of Maui, Defendant-Appellee-Cross-Appellant · filed 2002-02-20

The statute of limitations for tort actions regarding damage to persons or property under Hawaii law is two years from the date that the cause of action accrued. Haw.Rev.Stat. § 657-7. Plaintiffs state law claim for sexual harassment arose out of events beginning in 1995 and lasting through the fall of 1997. Her state court complaint of February 4, 1998 was therefore filed within the statute of limitations.

Section 657-7 requires actions seeking compensation for injury to persons or property to be instituted within two years after the cause of action accrues, subject to the exception in section 657-13.

Nam Soon Jeon v. 445 Seaside, Inc. · filed 2013-01-29

The AOAO moves for summary judgment, arguing in relevant part that the claims asserted against it are barred by the applicable two-year statute of limitations, section 657-7 of Hawaii Revised Statutes. This court agrees and grants summary judgment in favor of the AOAO with respect to the claims asserted against it in the Third Amended Complaint.

Section 657-7 supplies the two-year personal injury limitations period applied to Section 1983 claims.

Walter Rodenhurst, Iii v. Bauman · filed 2013-02-19

The district court properly dismissed as time-barred Rodenhurst’s claims stemming from his incarceration in Hawaii prior to his April 2006 transfer because Rodenhurst filed his complaint more than two years after exhausting administrative remedies for those claims.

Under Haw. Rev. Stat. § 657-7, a tort claim accrues when the plaintiff discovers, or through reasonable diligence should have discovered, the negligent act, the damage, and the causal connection between them.

Wada v. Aloha King, LLC · filed 2015-12-23

Pursuant to Haw. Rev. Stat. § 657-7, a tort claim accrues when the plaintiff discovers, or through the use of reasonable diligence should have discovered, the negligent act, the damage, and the causal connection between the two.

Under Haw. Rev. Stat. § 657-7, the limitations period begins when the plaintiff discovers or reasonably should discover the negligent act, the injury, and the causal connection between them.

Shook v. County of Hawaii Police Department · filed 2024-06-18

Haw. Rev. Stat. § 657-7 limitations period begins to run at “the moment plaintiff discovers or should have discovered the negligent act, the damage, and the causal connection between the former and the latter”

Section 657-7's two-year limitations period for injury claims begins when a childhood-sexual-abuse plaintiff discovers or reasonably should have discovered the psychological injury and its causal connection to the abuse, with the accrual date ordinarily left to the jury.

Dunlea v. Dappen · filed 1996-09-19

Under Hawai'i law, damage to persons or property is governed by HRS § 657-7, which provides that “[a]ctions for the recovery of compensation for damage for injury to persons or property shall be instituted within two years after the cause of action accrued, and not after, except as provided in section 657-13.” ... Because we agree that the issue of when Dunlea discovered, or should have discovered, that her alleged injuries were caused by Dappen’s alleged actions is a question of fact for the jury, we cannot hold as a matter of law that Dunlea ascertained her alleged injuries and their causal link to Dappen’s alleged actions more than two years before she asserted her claim, or that her failure to recognize her alleged injuries and the cause of those injuries sooner was unreasonable. Certainly, a reasonable jury could find that Dunlea filed suit within two years of discovering her alleged injuries and the cause of those injuries, given their nature and circumstances. We therefore hold that the motion to dismiss was wrongly granted. Accordingly, we vacate the circuit court’s dismissal of count III and remand this case for trial on Dunlea’s CSA claim.

Haw. Rev. Stat. § 657-7 covers claims for damages resulting from physical injury to persons or physical injury to tangible property interests, but the court left unresolved whether it applies to a regulatory inverse-condemnation claim.

Dw Aina Le'a Development, LLC v. State of Hawaii Land Use Comm · filed 2019-03-07

The Hawai‘i Supreme Court has interpreted § 657-7 to apply to “claims for damages resulting from physical injury to persons or physical injury to tangible interests in property,” but not to claims involving a “nonphysical injury to an intangible interest of [the] plaintiff.”

Haw. Rev. Stat. § 657-7 provides a two-year statute of limitations for personal-injury actions.

Gomes v. State of Hawaii · filed 2020-11-23

Hawaii’s statute of limitations for personal injury actions is two years.

Haw. Rev. Stat. § 657-7 imposes a two-year statute of limitations on negligence claims.

Ritchey v. Rando · filed 2021-09-21

Ritchey’s negligence claims are subject to a two-year statute of limitations. See Haw. Rev. Stat. § 657-7.

Haw. Rev. Stat. § 657-7 provides a two-year statute of limitations for personal-injury actions, including § 1983 claims using Hawaii's limitations period.

Malori v. Oahu Community Correctional Center (OCCC) · filed 2022-01-19

In Hawaii, the statute of limitations for personal injury actions is two years. See Haw. Rev. Stat. § 657-7; Bird v. Dep’t of Hum. Servs., 935 F.3d 738, 743 (9th Cir. 2019).

Haw. Rev. Stat. § 657-7 sets a two-year statute of limitations for personal injury actions.

Spriestersbach v. State of Hawaii · filed 2022-08-18

The Hawai`i statute of limitations for personal injury actions is two years. Haw. Rev. Stat. § 657-7.

Haw. Rev. Stat. § 657-7’s two-year limitations period applies to claims involving physical injury to a person or tangible property, while loss of an intangible property interest falls under the six-year period in § 657-1(4).

Field v. HSBC Bank USA, N.A. (In re Ho) · filed 2017-01-18§ 657-7

If the plaintiff seeks recovery for loss of an intangible property interest, Haw. Rev. Stat. § 657-l(4)’s six year statute of limitations applies.

The two-year limitations period in Haw. Rev. Stat. § 657-7 appears not to govern wrongful-foreclosure claims; the court left the issue unsettled.

Carpenter v. PNC Bank, N.A. · filed 2019-05-22§ 657-7

No Hawai'i appellate court has expressly held which statute of limitation applies to a wrongful foreclosure claim, although the two-year statute of limitations in ... appears to have been rejected.

Haw. Rev. Stat. § 657-7 imposes a two-year statute of limitations on intentional infliction of emotional distress claims.

Puana v. Kealoha · filed 2023-01-24

Plaintiffs’ IIED claim against Akagi has a two-year statute of limitations. See Haw. Rev. Stat. § 657-7; see also U.S. E.E.O.C. v. NCL Am., 535 F. Supp. 2d 1149, 1169 (D. Hawai`i 2006) (stating Haw. Rev. Stat. § 657-7 applies to IIED claims (citing Linville v. Hawaii, 874 F. Supp. 1095, 1104 (D. Haw. 1994)).

Haw. Rev. Stat. § 657-7 supplies a two-year limitations period for personal-injury actions in Hawaii, including as the forum-state period for § 1983 claims.

Nakaahiki v. Kauai Police Department · filed 2025-09-22

In general, the statute of limitations for personal injury actions in Hawaii is two years. See Haw. Rev. Stat. § 657-7; Bird v. Dep’t of Hum. Servs., 935 F.3d 738, 743 (9th Cir. 2019).

Haw. Rev. Stat. § 657-7 requires actions seeking compensation for injury to persons or property to be filed within two years after the cause of action accrues.

Kaipo · filed 2025-12-18

In Hawai‘i, the statute of limitations is two years. ... “Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued . . . .”

Haw. Rev. Stat. § 657-7 sets a two-year statute of limitations for personal-injury actions in Hawaii.

Kornegay · filed 2026-03-10

In general, the statute of limitations for personal injury actions in Hawaii is two years.

Section 657-7 sets a two-year limitations period for personal-injury actions, running from accrual of the cause of action.

Eto v. Muranaka · filed 2002-11-12

The statute of limitations for a personal injury action is “two years after the cause of action accrued, and not after[.]” HRS § 657-7 (1993). ... Similarly, here, Judge Chang determined that Plaintiff failed to serve the First Complaint within the six-month period allotted by RCCH Rule 28 and within the extended periods granted by the court prior to his May 1, 1998 order granting dismissal without prejudice. Plaintiff did not appeal this order. Although Judge Chang’s dismissal was without prejudice, the limitations period continued to run. By the time Plaintiff filed her Second Complaint, the statute of limitations had run, and the Second Complaint was time-barred.

Section 657-7 requires actions seeking compensation for injury to a person or property to be filed within two years after accrual, and the limitation applies based on the nature of the injury rather than the pleading's contract or tort label.

Gomez v. American Airlines, Inc. · filed 2006-05-23

The form of the pleading notwithstanding, it is both legally and intuitively obvious that Plaintiffs personal injury suit is governed and barred by the two-year, personal injury statute of limitations imposed by HRS § 657-7.

Haw. Rev. Stat. § 657-7's two-year limitations period applies to tort or product-liability claims based on personal injuries, not to a contract claim seeking contractual damages.

Construction Services Pacific, LLC v. Mule-Hide Products Co., Inc. · filed 2025-05-09

Such cases, however, are premised on allegations that the products caused the plaintiff’s personal injuries.

Section 657-7 requires property-damage actions to be filed within two years after accrual, but the limitations defense may be waived or lost through estoppel.

Mauian Hotel, Inc. v. Maui Pineapple Company · filed 1971-02-22

The Hawaii statute of limitations covering this situation requires an action to be instituted within two years after the claim accrued. ... It is general law that the statute of limitations is a personal defense and a person may waive the benefits of such statute. ... Therefore, we hold that since Austin-Smith, by the stipulation, may have contributed to Napili-Kai’s failure to file the cross claim within the period of the statute of limitations it is estopped from pleading the statute as a defense.

Section 657-7 requires actions for compensation for injury to persons or property to be filed within two years after the cause of action accrues, but disputed evidence of equitable estoppel may preclude a defendant from asserting the limitations bar on summary judgment.

Del Rosario v. Kohanuinui · filed 1971-03-24

When there is a disputed material factual issue as to whether a suit is timely brought, a defendant should not be granted summary judgment on the basis of the statute of limitations.

Section 657-7 covers actions seeking compensation for damage or injury to persons or property and places them among the personal tort actions to which chapter 657's tolling rules apply.

Kahale v. City and County of Honolulu · filed 2004-05-12

Inasmuch as HRS § 657-13 governs classes of “personal” tort actions, such as “[djamage to persons or property,” see HRS § 657-7, the infancy tolling provision of HRS § 657-13(1) applies directly to personal injury actions against the City.

Section 657-7 imposes a two-year limitations period on actions seeking compensation for physical injury to a person or tangible property, but it does not govern fraudulent nondisclosure or contract claims outside that category.

Lindgard v. RESIDUARY LIMITED PARTNERSHIP · filed 2006-12-27

Therefore, the circuit court incorrectly held that a two-year statute of limitations was applicable.

Section 657-7 applies to claims for damages from physical injury to persons or tangible property, but not to claims whose nature is fraudulent or negligent representation or breach of a contractual warranty merely because the alleged result was property damage.

Au v. Au · filed 1981-03-23

HRS § 657-7 has been interpreted to apply to “claims for damages resulting from physical injury to persons or physical injury to tangible interests in property.” ... However, the instant case does not involve the kinds of injury to which HRS §§ 657-7 and 657-1(1) would apply. Although the end result of the fraudulent representation was physical injury to appellant’s tangible interest in property, wherein HRS § 657-7 would seemingly apply, we believe that the instant case falls within the purview of HRS § 657-1 (4). ... The nature of this claim is not the physical injury to property, rather it is the making of the fraudulent representations concerning the condition of the home which induced appellant to purchase it.

Section 657-7 provides a two-year limitations period for the injuries at issue, but the court held that the six-year period in § 657-1(4) governs instead.

Au v. Au · filed 1981-03-23

Thus, the six-year limitations period in HRS § 657-1(4) rather than the two-year period in HRS § 657-7 applies.

Section 657-7 provides the two-year statute of limitations governing § 1983 actions in Hawaii.

Pele Defense Fund v. Paty · filed 1992-09-28

We hold that the two-year statute of limitations set forth in HRS § 657-7 governs § 1983 actions, rather than the six-year statute of limitations set forth in HRS § 657-1 (4).

Section 657-7 requires actions seeking compensation for injury to persons or property to be filed within two years after the cause of action accrues, subject to the exceptions in section 657-13, and applies to personal-injury-based emotional-distress and retaliatory-discharge claims.

Ellison v. Northwest Airlines, Inc. · filed 1996-05-08

In addition, any claim of intentional infliction of emotional distress (and for that matter any claim of negligent infliction of emotional distress) is subject to the two year statute of limitations in H.R.S. § 657-7, which states: Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued, and not after, except as provided in section 657-13 [disability by reason of infancy, insanity or imprisonment].

Section 657-7's two-year personal-injury limitations period applies to § 1983 actions in Hawaii, but accrual is deferred while related criminal charges are pending.

Pascual v. Matsumura · filed 2001-10-10

The statute of limitations applicable to § 1983 actions in Hawaii is Haw.Rev.Stat. § 657-7, the two-year, “general personal injury” provision. ... Accordingly, the court holds that Pascual’s § 1983 cause of action did not accrue while the criminal charges were pending against him.

Section 657-7's two-year limitation period begins when the plaintiff discovers or should have discovered the negligent act, the resulting damage, and the causal connection between them.

Yamaguchi v. Queen's Medical Center · filed 1982-07-13

We accept the Stoner rule as that which accords logically with the language of HRS § 657-7.3 and our position in Yoshizaki v. Hilo Hospital with respect to HRS § 657-7, by requiring the statute of limitations in effect to run the moment the plaintiffs cause of action accrues — that is, under HRS §§ 657-7 and 657-7.3, the moment plaintiff discovers or should have discovered the negligent act, the damage, and the causal connection between the former and the latter.

Section 657-7’s two-year personal-injury limitations period does not govern a breach-of-implied-warranty claim for goods when the UCC’s four-year limitations period applies.

Larsen v. Pacesetter Systems, Inc. · filed 1992-09-30

We have held, however, that plaintiffs claims are governed by the statute of limitations set forth in HRS § 490:2-725 rather than HRS § 657-7. Plaintiffs have therefore suffered no injury due to Pacesetter’s bad faith conduct, and the trial court correctly dismissed any of plaintiffs’ claims based thereupon.

Section 657-7 requires personal-injury and property-damage actions to be filed within two years after accrual; in strict-products-liability cases, accrual occurs when the plaintiff knows or reasonably should know of the manufacturer or seller, the dangerous defect, and that the defect caused the injury.

Agles v. Merck & Co., Inc. · filed 1995-02-01

Both parties agree that the applicable statute of limitation period is set forth in Hawaii Revised Statutes (“HRS”) § 657-7 which provides, in part, that “[a]ctions for the recovery of compensation for damage or injury to persons or property ... be instituted within two years after the cause of action accrued....” HRS § 657-7. ... The Hawaii Supreme Court has defined accrual as the moment a plaintiff discovers or reasonably should have discovered the negligent act, the damage, and the causal connection between the two. ... A slightly different test applies to strict products liability eases. A cause of action accrues as soon as a plaintiff knows or reasonably should know that: (1) a defendant is engaged in the business of manufacturing or selling a product, (2) the product contains a defect dangerous to the user or consumer, and (3) the defect is the cause of a plaintiffs injury.

Section 657-7’s two-year limitations period is not delayed until an injured plaintiff learns that the defendant owed an actionable legal duty.

Hays v. City and County of Honolulu · filed 1996-05-24

The purported deficiencies in Hays’s knowledge regarding both the city’s negligent act and the connection between the negligent act and his injury stem from Hays’s admitted lack of knowledge regarding the city’s legal duty to warn, which is a pure question of law, and, pursuant to Yamaguchi, the failure of which to discover does not delay the start of the two-year limitations period under HKS § 657-7. ... we nevertheless are compelled to hold that a plaintiffs lack of knowledge regarding a legal duty, the breach of which may have caused the plaintiff injury, will not justify application of the discovery rule.

Section 657-7’s two-year limitations period excludes the day the cause of action accrues and includes the corresponding anniversary date two years later.

Bauernfiend v. AOAO Kihei Beach Condominiums · filed 2002-10-01

Thus, reading HRS § 657-7 in pari materia with HRS § 1-29, the computation of time under the prescribed two-year statute of limitations would exclude the first day on which the cause of action accrues and include the last day, two years thereafter.

Section 657-7 gives tort causes of action a two-year statute of limitations.

Christiansen v. First Insurance Co. of Hawaii, Ltd. · filed 1998-04-22

The logical result of the holding in Best Place is that a limitation provision provided for in an insurance policy does not apply to an action in bad faith. As such, we hold that because an action for bad faith is an independent tort, the proper limitation provision should not be that provided in the policy, but rather, that provided in the state statute of limitations, HRS § 657-7 (1993), which limits causes of action for torts to two years.

Section 657-7 does not govern legal-malpractice claims for injury to an intangible interest; the six-year limitations period in § 657-1(1) governs instead.

Higa v. Mirikitani · filed 1973-12-11

We therefore hold that the timeliness of the plaintiff’s complaint is governed by the six-year limitations period of HRS § 657-1(1).

Section 657-7’s discovery rule starts the limitations period when the plaintiff discovers or should have discovered the negligent act, damage, and causal connection, not merely when the plaintiff learns the defendant’s identity.

Russell v. Attco, Inc. · filed 1996-05-08

the limitations period under HRS §§ 657-7 and 657-7.3 begins to run at the moment plaintiff discovers or should have discovered the negligent act, the damage, and the causal connection between the former and the latter.

Section 657-7 requires a tort action to be filed within two years after accrual, which occurs when the plaintiff discovers or reasonably should discover the negligent act, the damage, and the causal connection; factual knowledge is sufficient and legal knowledge of negligence is not required.

Association of Apartment Owners of Newtown Meadows Ex Rel. Board of Directors v. Venture 15, Inc. · filed 2007-07-31

HRS § 657-7 provides in relevant part that “[a]ctions for the recovery of compensation for damage or injury to per*277sons or property shall be instituted within two years after the cause of action accrued, and not after[.]” Under HRS § 657-7, a tort claim accrues when the plaintiff discovers, or through the use of reasonable diligence should have discovered, the negligent act, the damage, and the causal connection between the two. ... A plaintiff need only have factual knowledge of the elements necessary for an actionable claim; legal knowledge of a defendant’s negligence is not required. ... Thus, we hold that the circuit court erred when it concluded that the AOAO’s negligence claims were barred by HRS § 657-7 as a matter of law. Accordingly, we hold that the circuit court erred in granting summary judgment in favor of Venture 15, Geolabs, Royal, Lee, and Liu on the AOAO’s negligence claims based on HRS § 657-7.

Section 657-7 starts the limitations period when the plaintiff discovers, or through reasonable diligence should have discovered, the cause of action.

Hancock v. Kulana Partners, LLC · filed 2014-01-10

Claims for fraud, whether based on state or federal law, arise when the fraud is or should have been discovered. Mroz, 360 F.Supp.2d 1122, 1135 (citing First Interstate Bank v. Hartley, 681 F.Supp. 1457, 1460 (D.Haw.1988)); see also Assoc. of Apartment Owners of Newtown Meadows ex rel. its Bd. of Dirs. v. Venture 15, Inc., 115 Hawai’i 232, 270, 167 P.3d 225, 277 (2007) (Holding that under HRS § 657-7, “a claim accrues when the plaintiff discovers, or through the use of reasonable diligence should have discovered[,]” the cause of action.). ... The Court agrees with the decisions of those courts holding that a publicly recorded document, such as the Trustee Deed, provides constructive notice where the document itself constitutes evidence of the fraud. ... Accordingly, Plaintiff is charged with constructive knowledge of the contents of the Trustee Deed on the date it was recorded, August 28, 2002.

Section 657-7 provides a two-year limitations period for damage-to-persons-or-property claims, but it is less applicable to an IDEA attorney’s-fee action because that action does not sound in tort.

Brandon E. v. Department of Education · filed 2008-02-29

While it is not necessary in this case to determine whether the appropriate analogous statute of limitations is Hawaii’s two year statute (§ 657-7) or six year statute (§ 657-1(4)), as Plaintiffs complaint is timely in either case; nevertheless it seems to the Court that the essence of a fee action does not sound in tort and as such the six year catchall statute of limitations as codified in HRS § 657-1(4) is more applicable to the case at bar.

Section 657-7 requires actions seeking compensation for damage or injury to persons or property to be filed within two years after the cause of action accrues, subject to section 657-13.

Weidenbach v. Koolau Agricultural Co., Ltd. · filed 2009-03-03

As the most recent tortious activity occurred in December 1992 and the initial complaint was filed in 1998, the two-year provision in HRS § 657-7 bars the Weidenbachs' claims sounding in tort.

Section 657-7 requires an action seeking compensation for injury to persons or property, including an IIED claim, to be filed within two years after accrual, measured when the plaintiff knew or should have known the causal connection between the defendant’s conduct and the damage.

Kersh v. MANULIFE FINANCIAL CORP. · filed 2011-05-31

A plaintiff must bring an IIED claim -within two years after the claim accrues. See HRS § 657-7 (providing that “an action for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued”); Guillermo v. Hartford Life & Ace. Ins. Co., 986 F.Supp. 1334, 1336 (D.Haw.1997) (finding that HRS § 657-7 applies to IIED claims). Similar to the misrepresentation claim, this cause of action accrues when Plaintiff “knew or should have known of the causal connection between the defendant’s action and the damage done.”

Section 657-7 requires actions for compensation for damage or injury to persons or property to be filed within two years after accrual, and the court applied that period to IIED, NIED, negligence, gross negligence, and § 514B-105 claims.

Derosa v. Association of Apartment Owners of the Golf Villas · filed 2016-08-31

Section 657-7 states: "Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued, and not after, except as provided in section 657-13.” The exceptions listed in § 657-13 do not apply in the instant case.

Section 657-7's two-year statute of limitations does not apply to a wrongful-foreclosure claim, at least on the record and issue presented here.

Malabe v. Ass'n of Apartment Owners of Executive Ctr. · filed 2018-11-29

While the Circuit Court does not appear to have dismissed the wrongful foreclosure claim on the basis of the statute of limitations, we reject the AOAO's request for us to conclude that a cause of action for wrongful foreclosure is subject to the two-year statute of limitations provision under HRS § 657-7. See, e.g.,, Hunqate v. Law Office of David B. Rosen, 139 Hawai'i 394, 400, 391 P.3d 1, 7 (2017) (wherein the supreme court recognized the validity of a wrongful foreclosure claim in a complaint filed four years after the foreclosure sale at issue).

Section 657-7 provides a two-year limitations period for personal-injury claims, which this court treats as applicable to § 504 Rehabilitation Act claims in Hawaii.

Chun v. City and County of Honolulu · filed 2020-07-13

And, in Hawaii, the two-year personal injury statute of limitations is most analogous to a § 504 action. See Toma v. Univ. of Haw., 2017 WL 4782629, at *5 (D. Haw. Oct. 23, 2017) (finding that Hawaii’s two-year statute of limitations under HRS § 657-7 applies to claims under § 504 of the Rehabilitation Act); Jefferies v. Albert, 2009 WL 4064799, at *5 (D. Haw. Nov. 24, 2009) (same); Wiles v. Dep’t of Educ. Haw., 2006 WL 8436133, at *15 n.7 (D. Haw. Dec. 19, 2006) (same).

Section 657-7 gives negligence claims a two-year limitations period that begins when the plaintiff knew or should have known of the negligent act, damage, and causal connection.

Mansha Consulting LLC v. Alakai · filed 2017-02-16

In Hawaii, negligence claims are subject to a two-year statute of limitations pursuant to Hawaii Revised Statutes (“HRS”) § 657-7. ... Specifically,-HRS § 657-7 provides that causes of action for personal injury “shall be instituted within two years after the cause of action accrued.” Under Hawaii law, a claim “does not ‘accrue’ and the statute of. limitations in § 657-7 does not begin to run, until the plaintiff knew or should have known of the defendant’s negligence.” ... Accordingly, the “claim accrues ‘the moment plaintiff discovers or should have discovered the negligent act, the damage, and the causal connection between the former and the latter.’ ” ... Thus, Matsuda’s last day as Interim Executive Director does not represent the day the cause of action accrued if Mansha did not become aware of the damage from Matsuda’s alleged negligence and the causal connection between the damage and Matsuda’s .negligence until after Matsuda’s time in that position. ... Under these circumstances, it cannot be said that the running of the statute of limitations is apparent from the face of the Complaint. Accordingly, the Court denies Matsuda’s Motion to Dismiss on this basis.

Section 657-7 provides the same two-year limitation for county tort claims as for private tort-feasors after the unconstitutional special county provision is severed.

Silva v. City and County of Honolulu · filed 2007-08-10

“within two years after the cause of action accrued,” HRS § 657-7, they are entitled to pursue their claims.

Section 657-7’s two-year period did not limit an employee’s intervention in an employer’s timely filed third-party action.

First Insurance Co. of Hawaii v. a & B Properties, Inc. · filed 2012-03-14

For the foregoing reasons, we hold that HRS § 386-8 and 657-7 did not limit Toro’s intervention in First Insurance’s timely filed suit.

Section 657-7 does not govern a wrongful-foreclosure claim alleging nonphysical injury to intangible property interests; § 657-1(1) supplies the applicable limitations period instead.

Lowther v. U.S. Bank N.A. · filed 2013-09-04

Thus, this Court rejects Defendant’s argument that Count II is time-barred by § 657-7, and concludes that § 657-1(1) is the applicable statute of limitations.

Section 657-7’s limitations period is subject to cross-jurisdictional tolling while a related putative class action is pending elsewhere.

Patrickson v. Dole Food Company, Inc. · filed 2015-10-21

We hold that Hawaiʻi recognizes cross-jurisdictional tolling.

Section 657-7 does not apply to a regulatory-taking claim involving no physical injury to tangible property.

DW Aina Leʻa Development, LLC v. State of Hawaii Land Use Commission · filed 2020-12-17

Because no “physical injury to tangible interests in property” is involved in DW’s claim, HRS § 657-7 does not apply.

Section 657-7 imposes a two-year statute of limitations on tort actions.

Abing v. Evers · filed 2021-08-30

Plaintiffs’ tort claims against Defendants in their individual capacities is governed by the two-year statute of limitations for tort actions in HRS § 657-7.

Section 657-7 provides the general two-year statute of limitations for personal-injury claims, and class-action tolling is analyzed identically under section 657-7 and HRS § 46-72.

Coles v. City and County of Honolulu. · filed 2022-09-02

In 2007, the legislature extended HRS § 46–72’s limitations period from six months to “two years after the injuries accrued.” See 2007 Haw. Sess. Laws Act 152, § 8 at 284-85. This amendment conformed HRS § 46–72’s limitations period with that of the “general” personal injury statute of limitations found in HRS § 657-7 (2016). See Silva, 115 Hawai‘i at 8 n.6, 165 P.3d at 254 n.6. Because HRS § 46-72’s limitations period is now the same as that of HRS § 657-7, the City has no arguments available to it under HRS § 46–72 distinct from those available to other litigants under HRS § 657-7. The analysis as to any sort of tolling will be identical for HRS § 657-7 and HRS § 46–72.

Section 657-7 imposes a two-year limitations period on tort claims and governs 42 U.S.C. § 1983 actions.

Raquinio v. County of Hawai'i · filed 2024-04-12

They accrued at the latest on January 12, 2017, when he was released from custody. His complaint below was filed on April 22, 2019, over two years later. His claims are time-barred. HRS § 657-7 (2016); Pele Def. Fund v. Paty, 73 Haw. 578, 595, 837 P.2d 1247, 1259 (1992) (holding that two-year statute of limitations in HRS § 657–7 governs 42 U.S.C. § 1983 actions).

Section 657-7 is a statute of limitations for claims seeking damages for injury to persons or property; it does not itself create a cause of action.

Wideman v. Hickam Federal Credit Union · filed 2025-11-10

HRS § 657-7 (2016) is the statute of limitations governing claims "for damage or injury to persons or property[.]" It doesn't create a cause of action.

Section 657-7 provides a two-year statute of limitations for personal-injury claims, and that limitations period applies to claims under 42 U.S.C. § 1983.

Hammond · filed 2026-03-24

Hawaii’s two-year statute of limitations for personal injury claims, HRS § 657-7, applies to § 1983 claims.

Section 657-7 imposes a two-year limitations period on tort claims for breach of the insurance covenant of good faith and fair dealing and for interference with existing contractual relations.

Gilliam v. Elliot · filed 2022-06-17

This claim was subject to a two-year statute of limitations under HRS § 657-7. Gilliam's "Tortious Interference with Business Relationships" (Tortious Interference) claim generally asserted a claim for tortious interference with existing contractual relations, subject to the statute of limitations under HRS § 657-7. See Complaint ¶¶ 24 to 27; One Wailea Dev., LLC v. Warren S. Unemori Eng'g, Inc., No. CAAP-XX-XXXXXXX, 2016 WL 2941062 (App. Apr. 20, 2016), at *15 (mem.) (citing HRS § 657-7; Kutcher v. Zimmerman, 87 Hawai#i 394, 406, 957 P.2d 1076, 1088 (1998) (holding that a cause of action for interference with prospective contractual relations "run[s] parallel to that for interference with existing contracts[.]")) . Summary judgment was properly granted on this claim.

Section 657-7 is a limitations statute and does not itself create a cause of action.

Wideman v. Penhall Construction Company · filed 2025-07-29

HRS § 657-7 is a statute of limitations to bar a claim, and does not provide for ... a cause of action.

Section 657-7 imposes a two-year limitations period for tort claims seeking compensation for injury to persons or property, running from accrual when the plaintiff discovers or reasonably should have discovered the negligent act, damage, and causal connection.

In Re Agent Orange Product Liability Litigation · filed 1985-05-09

Plaintiffs' claim against the chemical companies and the University's Former Regents is governed by the two-year Hawaii statute of limitations for tort actions, which provides: Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued * * *. Haw.Rev.Stat. § 657-7 (1976). The Supreme Court of Hawaii has held that a claim accrues when the plaintiff discovers, or reasonably should have discovered, the "negligent act, the damage, and the causal connection between the former and the latter." Yamaguchi v. Queen's Medical Center, 65 Haw. 84, 648 P.2d 689, 693-94 (1982). ... The latest date on which plaintiffs may be said to have "discovered" the causal connection was September 1979, more than two years prior to institution of the Hawaii district court action. ... Accordingly, all claims of plaintiffs Oshita and Takatsuki against the chemical companies and the Former Regents of the University of Hawaii and all claims of plaintiff Fraticelli, other than for wrongful death, are barred.

Section 657-7 starts the two-year limitations period when the plaintiff knew or, with reasonable diligence, should have known that a claim existed; for personal injury, that includes knowing the defendant’s negligence or breach of duty may have caused the injury.

Carvalho v. Johns-Manville Sales Corp. · filed 1989-04-03

Hawaii Supreme Court precedent as well as our past decisions thus establish that the district court correctly interpreted § 657-7. Under Hawaii law, an action for personal injury or property damage accrues when the plaintiff knew or in the exercise of reasonable diligence should have known that she had a claim. In the personal injury context, knowledge of a claim involves knowledge that the defendant’s negligence or violation of a duty may have caused the injury.

Section 657-7's two-year limitations period incorporates a discovery rule, and in sexual-abuse cases accrues when the plaintiff discovers or should have discovered the negligent act, resulting damage, and causal connection.

Figueroa v. Bishop Joseph Ferrario, the Diocese of Honolulu the Church of Saint Anthony, in Kailua, Hawaii · filed 1993-07-06

To survive Hawaii's two-year statute of limitations, Haw.Rev.Stat. § 657-7, Figueroa urges application of the discovery rule, under which a cause of action does not accrue until the party "discovers or should have discovered the negligent act, the damage, and the causal connection between" the two. ... Hawaii case law indicates that Hawaii would extend the discovery rule to cases of sexual abuse. However, Figueroa's February 27, 1986, letter to the archbishop detailing his accusations against the defendants and the harm caused to him evidences the discovery that marks the commencement date for the statute of limitations. Figueroa's subsequent affidavit does not establish otherwise. ... The district court properly held that Figueroa's non-defamation claims were barred by the statute of limitations.

Section 657-7 imposes a two-year limitations period for personal-injury claims, accruing when the plaintiff discovers or should have discovered the injury and its physical cause; ignorance of the defendant's identity does not delay accrual.

Strand v. General Electric Co. · filed 1996-09-13

The court concludes .that Plaintiffs claims against Defendant for personal injury aecrued when Plaintiff discovered or should have discovered her injury caused by the silicone gel released into her body. Plaintiffs causes of action accrued upon her discovery of the injury, not the identity of Defendant GE as the putative supplier of the gel used in Plaintiffs implants. ... Whereas Defendant has demonstrated that Plaintiffs claim, for personal injury accrued before October 25, 1991, Plaintiffs claims against Defendant GE for such injuries are barred by operation of the two year statute of limitations. Haw.Rev.Stat. § 657-7.

Section 657-7 supplies a two-year limitations period for an independent IDEA action seeking only attorneys’ fees and costs after prevailing at the administrative level.

Holmes Ex Rel. Hitchens v. Department of Educ. · filed 2002-12-06

The Eleventh Circuit has held that a state’s general damages statute of limitations applies to independent IDEA actions seeking only fees (which would mean that the 2-year period in Haw.Rev.Stat. § 657-7 would apply). ... The Court has reviewed the reasoning from all the decisions and finds that the Eleventh Circuit’s position is proper. Therefore, the Defendant’s motion to dismiss is DENIED.

Section 657-7 uses a two-year limitations period measured from accrual, and under the discovery rule a claim accrues when the plaintiff knew or should have known of the defendant’s negligence.

Gast v. Sung Ki Kwak · filed 2005-10-17

Contrary to Plaintiffs’ assertions, Section 657-7 is not applicable to the wrongful death claims covered by Section 663-3, and therefore the discovery rule that has been read into that language is not applicable to Section 663-3 through the “except as otherwise provided” language.

Section 657-7 provides a two-year statute of limitations that begins when the alleged violation becomes apparent.

Heffner v. Young · filed 2007-04-03

Heffner’s claim that the DLNR’s order of September 2, 1999, violated her due process rights is time barred. Because the alleged violation became apparent when the order was issued, the two-year statute of limitations began to run at that time and expired before Heffner filed this action. See De Anza Props. X Ltd. v. County of Santa Cruz, 936 F.2d 1084, 1086 (9th Cir.1991); see also Haw.Rev.Stat. § 657-7.

Section 657-7 imposes a two-year limitations period on actions for injury to persons or property, and the claim accrues when the plaintiff discovers or reasonably should have discovered the elements connecting the defendant’s conduct to the harm.

U.S. Equal Employment Opportunity Commission v. NCL America, Inc. · filed 2008-02-20

“[A]n action for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued.” Haw.Rev.Stat. § 657-7. The two-year limitations period applies to claims for emotional distress filed in federal court. ... Under the discovery rule, “a cause of action accrues when the plaintiff discovers, or reasonably should have discovered, the elements giving rise to the claim.” ... There is a triable issue of fact as to when PlaintiffsIntervenors discovered the cause of their alleged emotional distress.

For IIED and NIED claims, the two-year limitations period under § 657-7 accrues when the plaintiff knew or should have known the causal connection between the defendant’s conduct and the resulting injury.

Caraang v. PNC Mortgage · filed 2011-06-20

At the outset, the Court must address the PNC Defendants’ argument that Plaintiffs’ IIED and NIED claims are barred by the statute of limitations in Haw.Rev. Stat. § 657-7, which states, in pertinent part, that: “Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued, and not after....” ... Similarly, in the present case, it is unclear when Plaintiffs suffered their emotional distress and when they connected it with the PNC Defendants’ actions. Thus, at this time, the Court cannot find that Plaintiffs’ IIED and NIED claims are time-barred.

Section 657-7 requires actions seeking compensation for injury to persons or property to be filed within two years after accrual, and the discovery rule applies to IIED and NIED claims when the timing of the plaintiff’s discovery is unclear.

Enriquez v. Countrywide Home Loans, FSB · filed 2011-08-31

At the outset, the Court must address Countrywide’s argument that Plaintiffs IIED and NIED claims are barred by the statute of limitations in Haw.Rev.Stat. § 657-7, which states, in pertinent part, that: “Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued, and not after.... ” Plaintiffs IIED and NIED claims are based primarily upon events that occurred during loan origination. Plaintiff filed this action on July 16, 2010. Although Plaintiff entered into the loan in July 2007, more than two years prior to the filing of the Complaint, the “discovery rule” applies to the statute of limitations for IIED and NIED claims. ... Similarly, in the present case, it is unclear when Plaintiff suffered her emotional distress and when she connected it with Countrywide’s actions. Thus, at this time, the Court cannot find that Plaintiffs IIED and NIED claims are time-barred.

Section 657-7 provides a two-year limitations period for § 1983 actions, subject to tolling under the continuing-violations doctrine when the alleged violations are part of an ongoing pattern of unlawful conduct.

Allen v. Iranon · filed 1999-07-15

In Hawaii, the statute of limitations for actions under Section 1983 is two years from the date of the violation. ... However, the continuing violations doctrine tolls the statute of limitations for alleged violations that form part of a pattern of ongoing unlawful conduct. ... Here, the Court finds that the statute of limitations does not bar any of Plaintiffs claims, since all of the allegations are sufficiently related to constitute a continuing violation.

Section 657-7 bars the prisoner’s § 1983 access-to-courts claims accruing before April 24, 1991 under Hawaii’s applicable statute of limitations.

Martinez v. Neilson · filed 1996-12-20

We affirm the district court's dismissal of Martinez's access to the courts claims because, as the district court noted, any claims occurring before April 24, 1991 are barred by Hawaii's statute of limitations. See Owens v. Okure, 488 U.S. 235, 249-50 (1988); Haw.Rev.Stat. § 657-7.

Section 657-7 imposes a two-year limitations period on negligence, strict liability, trespass, and nuisance claims for damage or injury to persons or property; a continuing tort can toll the period, but recovery is limited to the two years preceding suit.

Aana v. Pioneer Hi-Bred International, Inc. · filed 2013-08-09

Assuming, for purposes of Defendants’ Motion, that Plaintiffs can state a plausible strict liability claim under the facts of this case,9 the two-year statute of limitations period in § 657-7 also applies to Count IV. ... Section 657-7 also applies to Plaintiffs’ trespass claim (Count V). ... Plaintiffs’ allegations in their nuisance claim (Count VI), however, clearly describe “damage or injury to persons or property,” and therefore this Court concludes that § 657-7 also applies to Count VI.

Section 657-7's limitations period is not tolled by alleged mental incapacity following mercury exposure when the plaintiff had given his wife a power of attorney.

McWherter v. CBI Services, Inc. · filed 1997-01-09

McWherter agrees that Haw.Rev.Stat. § 657-7 sets the limitations period, but argues that there is an issue of fact as to whether the statute was tolled by his mental incapacity following his mercury exposure. We disagree, given the power of attorney given to Mrs. McWherter on August 21, 1991.

Claims that would otherwise fall under § 657-7 are subsumed by Hawaii's wrongful-death statute, § 663-3, in a wrongful-death action.

Bailey v. United States · filed 2003-10-10

In any event, claims that might otherwise be governed by section 657-7 are subsumed by section 663-3.

Section 657-7 imposes a two-year limitations period for tort claims, running when the plaintiff discovers or should have discovered the negligent act, the damage, and the causal connection; a constructive-discharge claim accrues when the discharge occurs.

Leong v. Hilton Hotels Corp. · filed 1988-06-13

Under Hawaii law, the statute of limitations begins to run when a person discovers or should have discovered the negligent act, the damage, and the causal connection between the two. ... The damage alleged in the wrongful constructive discharge claim is, of course, the discharge of Leong, which did not occur until September 1986, well within the two year limitations period. ... The constructive discharge claim alleges that cumulative actions of the employer over time caused the damage, which damage actually occurred later.

Section 657-7 requires tort actions seeking compensation for injury to persons or property to be filed within two years after the cause of action accrues; accrual occurs when the plaintiff discovers or reasonably should have discovered the negligent act, damage, and causal connection.

Fraticelli v. Dow Chemical Co. · filed 1985-05-09

Plaintiffs’ claim against the chemical companies and the University’s Former Regents is governed by the two-year Hawaii statute of limitations for tort actions, which provides: Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued * * *. Haw.Rev.Stat. § 657-7 (1976). The Supreme Court of Hawaii has held that a claim accrues when the plaintiff discovers, or reasonably should have discovered, the “negligent act, the damage, and the causal connection between the former and the latter.” Yamaguchi v. Queen’s Medical Center, 65 Haw. 84, 648 P.2d 689, 693-94 (1982). ... The latest date on which plaintiffs may be said to have “discovered” the causal connection was September 1979, more than two years prior to institution of the Hawaii district court action. ... Accordingly, all claims of plaintiffs Oshita and Takatsuki against the chemical companies and the Former Regents of the University of Hawaii and all claims of plaintiff Fraticelli, other than for wrongful death, are barred.