Wong v. Thompson — Hawaiʻi appeals court affirms judgment after tenant failed to provide an adequate appellate record

Case
Damien Wong v. Tamara Thompson
Court
Intermediate Court of Appeals of the State of Hawaiʻi
Judge
Katherine G. Leonard (Linda Lingle, 2008); Clyde J. Wadsworth (David Y. Ige, 2019); Kimberly T. Guidry (Josh Green, 2023)
Date Decided
September 14, 2026
Docket No.
CAAP-24-0000760
Topics
landlord-tenant; appellate procedure; inadequate record; self-represented litigants
Source
Read the full opinion

Background

Damien Wong obtained an October 15, 2024 judgment against Tamara Thompson after a bench trial in the District Court of the Third Circuit, North and South Kona Division. Thompson, who represented herself, appealed as a defendant and counterclaimant.

On appeal, Thompson argued that the district court improperly weighed evidence of Wong’s negligence and its effect on her health, disregarded a landlord’s obligations under state and local housing laws, and was biased in Wong’s favor.

The Court’s Holding

The Intermediate Court of Appeals affirmed. Thompson did not identify points of error as required by Hawaiʻi Rule of Appellate Procedure 28(b)(4), cite where the claimed errors occurred in the record, or show that she raised objections in the district court.

She also did not provide trial transcripts. Without a record supporting review of the evidence, legal claims, or alleged bias, the court concluded that her contentions afforded no basis for appellate relief.

Key Takeaways

  • An appellant must identify alleged errors and support them with record citations.
  • Trial transcripts may be necessary to obtain appellate review of claimed trial-level error.
  • Unsupported claims concerning evidentiary weighing, legal error, or judicial bias will not warrant reversal.

Why It Matters

The order underscores that appellate courts review the record presented, not unsubstantiated assertions in a brief. Self-represented appellants remain responsible for meeting briefing and record-preparation requirements.

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