Espina v. Seno

Summary

The Hawaiʻi Intermediate Court of Appeals reviewed a Family Court sanctions order against a self-represented party for failing to submit required pretrial and settlement documents. The court held that the cited rules authorized sanctions only against attorneys, not self-represented litigants, and reversed the sanctions order while dismissing all pending motions.

Holdings

1. The Intermediate Court of Appeals had appellate jurisdiction under the collateral order doctrine because the sanctions order required Seno to pay a specific amount by a specific date and was immediately enforceable through contempt proceedings.
2. Hawaiʻi Family Court Rules Rule 89 and Rules of the Circuit Courts of the State of Hawaiʻi Rule 15 did not authorize the sanctions imposed against Seno because those rules authorize sanctions or discipline only against attorneys, and Seno was self-represented.

Questions Presented

1. Whether the Intermediate Court of Appeals had appellate jurisdiction to review the sanctions order under the collateral order doctrine.
2. Whether Hawaiʻi Family Court Rules Rule 89 and Rules of the Circuit Courts of the State of Hawaiʻi Rule 15 authorized sanctions against a self-represented party for failing to submit required court documents.

Disposition

reversed