In re Holzman Trust — Hawaiʻi Supreme Court denies mandamus petition over unsigned TRO motion

Case
In the Matter of the Alan S. Holzman Trust
Court
Supreme Court of Hawaiʻi
Judge
Devens, C.J. (Josh Green, 2024); McKenna, J. (Neil Abercrombie, 2011); Eddins, J. (David Ige, 2020); Ginoza, J. (Josh Green, 2024); Circuit Judge Kimura, assigned by reason of vacancy (Josh Green, 2023)
Date Decided
November 2, 2026
Docket No.
SCPW-26-0000474
Topics
mandamus; probate; temporary restraining orders; filing requirements
Source
Read the full opinion

Background

This original proceeding concerned the Alan S. Holzman Trust. The petitioner sought a writ of mandamus arising from Circuit Court case No. 1CTR-26-0000054.

The petitioner relied on a motion for a temporary restraining order purportedly filed on June 16, 2026, at docket 36. The Supreme Court determined that the motion actually filed at that docket was unsigned.

The Court’s Holding

The Supreme Court of Hawaiʻi denied the petition for writ of mandamus. It held that the petitioner had not shown a clear and indisputable right to relief because the underlying temporary-restraining-order motion was unsigned.

The court cited Womble Bond Dickinson (US) LLP v. Kim and Hawaiʻi Probate Rules Rule 5(a). It also directed the clerk to process the petition without filing fees, denied the request to seal docket 2, and denied a motion filed July 8, 2026.

Key Takeaways

  • Mandamus requires a clear and indisputable right to relief.
  • An unsigned motion does not support the requested extraordinary relief in this proceeding.
  • The court separately allowed fee-free processing while denying sealing and other requested relief.

Why It Matters

The order underscores that procedural filing requirements can be dispositive in extraordinary-writ proceedings. A party seeking mandamus must ensure that the underlying filing complies with applicable signature rules before asserting a clear entitlement to relief.

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