Murphy v. Widawsky — appeal dismissed for failure to file required appellate documents

Case
Cynthia Murphy v. William T. Widawsky
Court
Intermediate Court of Appeals of the State of Hawaiʻi
Judge
Keith K. Hiraoka; Clyde J. Wadsworth; Daniel M. Gluck
Date Decided
October 1, 2026
Docket No.
CAAP-26-0000123
Topics
Appellate procedure; Dismissal; Pro se litigants
Source
Read the full opinion

Background

Cynthia Murphy was the petitioner-appellee, and William T. Widawsky, representing himself, appealed from the District Court of the First Circuit, Honolulu Division.

Widawsky’s statement of jurisdiction was due May 25, 2026, and his opening brief was due June 24, 2026. He filed neither document and did not seek an extension of time.

The Court’s Holding

After the appellate clerk issued a July 22, 2026 default notice, Widawsky still took no action. The notice advised that the appeal could be dismissed under Hawaiʻi Rules of Appellate Procedure Rules 12.1(e) and 30 and that he could seek relief from default by motion.

The Intermediate Court of Appeals dismissed the appeal because Widawsky failed to file the required statement of jurisdiction and opening brief, did not request more time, and did not respond to the default notice.

Key Takeaways

  • An appellant must timely file the statement of jurisdiction and opening brief.
  • A default notice may warn that an appeal is subject to dismissal and provide an opportunity to seek relief.
  • Failure to act after a default notice can result in dismissal of the appeal.

Why It Matters

The order illustrates that self-represented appellants remain responsible for complying with appellate filing deadlines. An appeal may be dismissed when required appellate documents are not filed and the appellant does not seek an extension or relief from default.

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