Background
In March 2019, the Family Court of the First Circuit entered an agreed order requiring E.F. (Father) to pay C.L., now known as C.S. (Mother), $2,000 in child-support-care arrears and $905.04 per month in current support through Hawaii’s Child Support Enforcement Agency (CSEA). Father did not appeal that order.
More than five years later, Father moved to void the 2019 order, seeking related relief including reimbursement for alleged child-care overpayments. The family court denied the motion and later denied reconsideration and a new trial. Father, proceeding pro se, appealed.
The Court’s Holding
The Intermediate Court of Appeals affirmed. It held that the challenged findings concerning Father’s prior CSEA proceedings, his failure to appeal the CSEA order, and the issues set for the extended hearing were supported by the record or accurately stated it. The court also concluded that Father lacked a legal basis to set aside the agreed 2019 order after more than five years, particularly because he had not appealed it and the CSEA order was res judicata as to that order.
The court rejected Father’s apparent contention that the absence of a Child Support Guidelines Worksheet rendered the 2019 order void under Hawaii Family Court Rules Rule 60(b)(4). A judgment is void under that rule only for lack of subject-matter jurisdiction, lack of personal jurisdiction, or a due-process violation; none was shown. The court affirmed the October 15 and December 16, 2024 orders and denied all pending motions.
Key Takeaways
- An alleged defect in child-support documentation does not by itself make an order void under Rule 60(b)(4).
- Rule 60(b)(4) relief is limited to jurisdictional or due-process defects.
- Appellants must connect their arguments to identified points of error; unargued points may be waived.
Why It Matters
The decision underscores the narrow scope of void-judgment relief in Hawaii family cases. Parties seeking to challenge an older child-support order must identify a jurisdictional or due-process defect, rather than merely assert that the underlying calculation or supporting paperwork was deficient.