Background
Jamie Jeffrey Habig filed an original proceeding in the Supreme Court of Hawaiʻi seeking extraordinary writ relief in connection with a probate matter (Case No. 5CLP-25-0000079) then on appeal before the Intermediate Court of Appeals (CAAP-25-0000840). Habig’s initial petition was filed December 24, 2025, followed by additional petitions on April 21, 2026.
Throughout the appellate proceedings, Habig filed numerous documents with the court. The record also revealed procedural irregularities, including filings that contained sensitive personal information — a certified Hawaii birth certificate and a full financial account number — as well as two dockets (27 and 185) that Habig sought to place under seal without satisfying the procedural and substantive requirements for sealing.
The Court’s Holding
The Supreme Court denied all of Habig’s petitions for extraordinary writ relief. The court held that an extraordinary writ is unwarranted where the petitioner has access to normal appellate procedures for reviewing the probate court’s decisions, citing Womble Bond Dickinson (US) LLP v. Kim, 153 Hawaiʻi 307, 319, 537 P.3d 1154, 1166 (2023). The court further found the Intermediate Court of Appeals’ pace of review not unreasonable, especially given the volume of filings Habig submitted during the appeal.
The court ordered two dockets stricken: Docket 32, because it contained a certified Hawaii birth certificate in violation of Hawaiʻi Revised Statutes § 338-18 and Hawaiʻi Court Records Rules (HCRR) Rules 2.19 and 9; and Docket 180, because it contained a full account number in violation of the same HCRR rules. Regarding Dockets 27 and 185, which Habig sought to seal, the court found he had not complied with the requirements set out in State v. Rogan, 156 Hawaiʻi 233, 243, 573 P.3d 616, 626 (2025), and gave him ten days to file a proper motion justifying the seal or face unsealing of those dockets. Habig’s application to proceed in forma pauperis was denied as moot.
Key Takeaways
- Extraordinary writ relief is unavailable where normal appellate procedures provide an adequate avenue for review of the lower court’s decisions.
- A high volume of filings by a petitioner during an appeal does not render the appellate court’s timeline unreasonable for purposes of extraordinary writ intervention.
- Filings containing statutorily protected information (birth certificates under HRS § 338-18) or sensitive financial data (full account numbers) are subject to being stricken under the Hawaiʻi Court Records Rules.
- A party seeking to seal court records must satisfy both procedural and substantive requirements; failure to do so may result in the documents being unsealed.
Why It Matters
This order reinforces the high bar for obtaining extraordinary writ relief in Hawaiʻi courts — parties dissatisfied with probate rulings must exhaust normal appellate channels before the Supreme Court will intervene. It also serves as a practical reminder that litigants, particularly self-represented ones, must carefully comply with court records rules before submitting documents containing sensitive personal or financial information, as violations can result in those filings being stricken from the record entirely.