Background
Eric Magazu, representing himself, was the subject of a civil traffic infraction proceeding in the District Court of the Fifth Circuit, Līhuʻe Division. The district court entered a Judgment and Notice of Entry of Judgment on December 19, 2024. Magazu later sought post-judgment relief, and the district court entered a second judgment on March 10, 2026, followed by a March 18, 2026 ruling denying his motion for reconsideration of an order that had itself denied his motion to set aside the March 10 judgment.
Magazu appealed all three rulings to the Hawaiʻi Intermediate Court of Appeals. The ICA undertook a sua sponte review of its own appellate jurisdiction before reaching the merits.
The Court’s Holding
The ICA dismissed the appeal for lack of appellate jurisdiction. Under Hawaiʻi Civil Traffic Rules (HCTR) Rule 19(d), appeals from civil traffic cases may only be taken from a judgment entered after a trial requested pursuant to Hawaiʻi Revised Statutes § 291D-13(a). The December 19, 2024 Judgment was not entered after such a trial and therefore was not an appealable final judgment.
Because the underlying December 19, 2024 Judgment was non-appealable, the two subsequent post-judgment orders were likewise non-appealable — a non-final judgment cannot supply the appellate foundation required for review of orders that merely flow from it. The dismissal was entered without prejudice, leaving Magazu free to seek relief at the district court level under HCTR Rule 18.
Key Takeaways
- In Hawaiʻi civil traffic infraction cases, the only appealable judgment is one entered after a trial held pursuant to HRS § 291D-13(a); judgments reached through other dispositions do not carry appellate rights.
- Post-judgment orders (including rulings on motions to set aside or for reconsideration) are not independently appealable when the underlying judgment is itself non-appealable.
- The ICA has an independent, non-waivable obligation to examine its own jurisdiction and must dismiss sua sponte when a jurisdictional defect is apparent.
- Dismissal for lack of jurisdiction was without prejudice, preserving the defendant’s ability to pursue district-court remedies under HCTR Rule 18.
Why It Matters
This decision reinforces a consistent line of ICA authority limiting appellate access in civil traffic cases to a narrow procedural gateway — the post-trial judgment. Litigants, including pro se defendants, who attempt to appeal district court traffic rulings entered without a formal trial will find the appellate door closed regardless of how many post-judgment motions they file.
Practitioners advising clients on traffic infraction matters should counsel that the right to appeal is conditioned on first requesting and obtaining a trial under HRS § 291D-13(a). Bypassing that step — whether through admission, mitigation hearings, or other non-trial dispositions — forecloses appellate review and limits relief to district-court mechanisms.