Background
Beau Hawkes, a self-represented plaintiff, appealed a decision from the Circuit Court of the Second Circuit (Case No. 2CCV-25-0000184) against defendants Chelsea Davis and Hawaiʻi News Now. On July 10, 2026, the Intermediate Court of Appeals issued an order dismissing Hawkes’s appeal. That same day, Hawkes filed a motion for reconsideration under Hawaiʻi Rules of Appellate Procedure (HRAP) Rules 40 and 26(b), seeking relief from the dismissal.
The Court’s Holding
The Intermediate Court of Appeals denied Hawkes’s motion for reconsideration. The court found that Hawkes failed to demonstrate a point of law or fact that the court had overlooked or misapprehended in the July 10 dismissal order. Under HRAP Rule 40(b), a motion for reconsideration must identify specific points of law or fact that the court failed to consider or misunderstood. Hawkes’s submission did not meet this requirement, and the court therefore had no basis to reconsider its dismissal order.
Key Takeaways
- Motions for reconsideration require the moving party to identify a specific point of law or fact that the court overlooked or misapprehended.
- Self-represented litigants are held to the same procedural standards as attorneys and must comply with appellate rules.
- Merely filing a motion without demonstrating legal or factual error does not warrant relief under HRAP Rule 40(b).
Why It Matters
This order illustrates that appellate courts apply procedural requirements uniformly, regardless of whether a party is represented by counsel. Self-represented litigants cannot bypass established appellate procedures, and conclusory or insufficient motions for reconsideration will be denied without further review.