Background
Lam Hawaii Inc. brought an eviction proceeding against Samantha Iopa in the District Court of the Third Circuit, North and South Hilo Division. Iopa, representing herself, appealed from the underlying case.
Iopa’s statement of jurisdiction and opening brief were due January 20 and February 17, 2026, respectively. She filed neither document, requested no extension, and took no action in the appeal after filing a motion for waiver of costs on November 24, 2025.
The Court’s Holding
The Hawaiʻi Intermediate Court of Appeals dismissed the appeal. The court noted that the appellate clerk issued a default notice warning Iopa that her filing deadlines had expired and that the appeal could be dismissed under Hawaiʻi Rules of Appellate Procedure Rules 12.1(e) and 30.
The clerk’s notices were returned as undeliverable and unable to forward. District court minutes indicated that Iopa had left the property she identified as her mailing address, but she did not file a notice of change of address as required by HRAP Rule 25(f) or seek relief from the default.
Key Takeaways
- An appellant’s failure to file a statement of jurisdiction and opening brief can result in dismissal of the appeal.
- A self-represented litigant remains responsible for complying with appellate deadlines and procedural rules.
- Parties must notify the appellate court of an address change so that court notices can be delivered.
Why It Matters
The order underscores that an appeal may end without consideration of its merits when the appellant does not prosecute it or maintain current contact information. The court dismissed solely on procedural grounds and did not decide any substantive issue arising from the eviction proceeding.