Anderson v. Ketchmark — Affirmed; Appellant Failed to Present Points of Error

Case
Trula Anderson v. Truman Lee Ketchmark
Court
Hawaii Intermediate Court of Appeals
Judge
Karen T. Nakasone (David Y. Ige, 2020)
Date Decided
July 16, 2026
Docket No.
CAAP-24-0000377
Topics
Appellate procedure, failure to present points of error, summary disposition
Source
Read the full opinion

Background

Ketchmark appealed from the Circuit Court of the First Circuit’s April 5, 2024 Findings of Fact, Conclusions of Law, and Order, which was entered following a jury-waived trial in case 1CCV-22-0000359. The Circuit Court’s final judgment was entered on May 18, 2026. Ketchmark, representing himself on appeal, filed his notice of appeal on April 19, 2024.

The Court’s Holding

The Intermediate Court of Appeals affirmed the Circuit Court’s judgment. The appellate court found that Ketchmark failed to identify any points of error on appeal, did not challenge any of the Circuit Court’s findings of fact or conclusions of law, and made no discernible argument that the trial court had erred. Because the appellant presented no cognizable issues for appellate review, the court found no basis for appellate relief and affirmed the judgment without addressing the merits of the underlying dispute.

Key Takeaways

  • An appellant must identify and argue specific points of error to obtain appellate review; vague assertions of error are insufficient.
  • Failure to challenge findings of fact or conclusions of law forfeits appellate consideration of trial court decisions.
  • Summary disposition orders may affirm judgments when an appellant fails to meet basic appellate brief requirements.

Why It Matters

This summary disposition order serves as a reminder that appellate procedure requires specificity. Self-represented litigants and counsel alike must clearly identify points of error and support them with legal argument and factual references to the record; generic complaints about trial court error do not survive appellate scrutiny. The court’s affirmance reinforces that appellate review is not a second chance to relitigate cases without adhering to procedural requirements.

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