Background
Hye Ja Choi appealed from a case in the District Court of the First Circuit, Honolulu Division. On August 10, 2026, the Intermediate Court of Appeals issued a summary disposition order.
Choi sought reconsideration of that order. The court had extended her deadline to file a reconsideration motion through August 31, 2026, but Choi filed her motion on September 1.
The Court’s Holding
The Intermediate Court of Appeals denied Choi’s motion for reconsideration. It held that the motion was untimely despite the previously granted extension.
The court further concluded that the motion identified no point of law or fact that the court had overlooked or misapprehended, as required by Hawai‘i Rules of Appellate Procedure Rule 40(b).
Key Takeaways
- A reconsideration motion filed after an extended deadline remains untimely.
- The court may also deny reconsideration because the motion identifies no overlooked or misapprehended legal or factual point.
- The amended order did not revisit the merits of the August 10 summary disposition order.
Why It Matters
The order underscores that reconsideration is a narrow appellate remedy, not an opportunity to relitigate a decision without identifying a specific error the court missed.
It also illustrates the importance of complying with appellate deadlines, including deadlines extended by court order.