In re Pauline — Hawaii Supreme Court denies extraordinary-writ petition

Case
In re Elden Pauline
Court
Supreme Court of Hawaiʻi
Judge
Devens, C.J.; McKenna, J.; Eddins, J.; Ginoza, J.; Toʻotoʻo, Circuit Judge
Date Decided
August 28, 2026
Docket No.
SCPW-25-0000883
Topics
Extraordinary writs; Criminal procedure; Original proceedings
Source
Read the full opinion

Background

Elden Pauline filed a document on December 22, 2025, which the Supreme Court of Hawaiʻi construed as a petition for an extraordinary writ. The proceeding arose alongside CAAP-25-0000053 and Circuit Court case 1CPN-24-0000029.

The order does not describe Pauline’s requested relief or the underlying facts. The court considered the filing and the record in the original proceeding.

The Court’s Holding

The Supreme Court denied the petition. It held that Pauline had not shown a clear and indisputable right to the requested relief or that no alternative means existed to obtain it.

Because those prerequisites were not established, an extraordinary writ was unwarranted. The court cited Womble Bond Dickinson (US) LLP v. Kim and Hawaiʻi Rules of Penal Procedure Rule 40.

Key Takeaways

  • Extraordinary-writ relief requires a clear and indisputable right to relief.
  • A petitioner must also show the absence of alternative means to obtain the requested relief.
  • The court denied the petition without addressing the merits of the underlying matter.

Why It Matters

The order reinforces the narrow, exceptional role of extraordinary writs in Hawaiʻi appellate practice. Litigants seeking original writ relief must demonstrate both entitlement to immediate intervention and the lack of another available procedural avenue.

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