DeJean v. Nago

Summary

The Supreme Court of Hawaiʻi dismissed Khistina Caldwell DeJean’s challenge to the November 2014 general election. The court held that DeJean lacked standing under Hawaiʻi Revised Statutes § 11-172 and failed to allege specific errors or irregularities sufficient to change the election results.

Holdings

1. DeJean lacked standing to contest the November 4, 2014 general election because she was not a candidate listed on the ballot, was not a qualified political party, and did not comprise thirty voters of an election district.
2. The complaint failed to state a claim because DeJean did not present specific facts or actual information of mistakes, errors, or irregularities sufficient to change the result of the general election.

Questions Presented

1. Whether DeJean had standing under HRS § 11-172 to contest the November 4, 2014 general election.
2. Whether DeJean’s election complaint stated a claim upon which relief could be granted under Hawaiʻi election-contest law.

Disposition

dismissed