Background
Reynaldo Valdes-Paz, a prisoner at the Halawa Correctional Facility, filed a petition for writ of habeas corpus directly with the Hawaii Supreme Court on June 3, 2026. The respondents were the Chairperson of the Hawaii Paroling Authority, the Director of the Department of Corrections and Rehabilitation, and the Warden of Halawa Correctional Facility.
Petitioner sought original habeas relief from the state’s highest court rather than initiating post-conviction proceedings in the circuit court. The Supreme Court considered the petition on an expedited basis given the nature of the claim.
The Court’s Holding
The Supreme Court denied the petition without prejudice, holding that no special reason existed to invoke the court’s original jurisdiction. The court noted that expedited relief is available to the petitioner in the circuit court through the post-conviction process under Hawaii Rules of Penal Procedure Rule 40(d), which allows courts to shorten response times where a petitioner makes a showing of entitlement to immediate relief.
The court further relied on established precedent — including Eason v. State, 157 Hawaiʻi 252 (2025), and Oili v. Chang, 57 Haw. 411 (1976) — for the principle that habeas petitions requiring an evidentiary hearing must be filed in the circuit court rather than directly in the Supreme Court, even though the Supreme Court holds concurrent jurisdiction.
Key Takeaways
- The Hawaii Supreme Court will decline to exercise original habeas jurisdiction when adequate and expedited relief is available to the petitioner in the circuit court.
- Habeas corpus petitions that require an evidentiary hearing must be filed in the circuit courts, not the Supreme Court, under longstanding Hawaii precedent.
- Denial without prejudice preserves the petitioner’s right to pursue relief through the proper post-conviction channel — a Rule 40 petition in circuit court — including on an expedited basis.
Why It Matters
This order reinforces the Hawaii Supreme Court’s consistent practice of reserving its original habeas jurisdiction for cases presenting truly exceptional circumstances. Practitioners should be aware that routing a habeas petition directly to the Supreme Court — even one seeking urgent relief — will ordinarily be turned away in favor of the circuit court’s Rule 40 process, which itself affords mechanisms for expedited handling.
For incarcerated individuals and their counsel, the decision underscores that the circuit court remains the proper and fully functional forum for post-conviction habeas claims, and that the Supreme Court’s concurrent jurisdiction is not a shortcut around that process absent a demonstrated special reason.