Iwamoto v. Medeiros, Jr.

Summary

The Hawaiʻi Intermediate Court of Appeals held that the defendant sufficiently raised a title-to-real-estate defense under Hawaiʻi District Court Rules of Civil Procedure Rule 12.1. Because title was placed in issue, the district court lacked jurisdiction under Hawaiʻi Revised Statutes § 604-5(d) to enter a writ and judgment for possession. The court vacated the November 13, 2023 writ and judgment and remanded for further proceedings.

Holdings

1. Medeiros sufficiently raised a claim to title because his Rule 12.1 motion and declaration identified the source, nature, and extent of his claimed interest in the property.
2. The District Court lacked jurisdiction under HRS § 604-5(d) once Medeiros sufficiently raised a claim that title to the property was in issue, and therefore erred in entering judgment against him.

Questions Presented

1. Whether Medeiros sufficiently asserted a defense of title under DCRCP Rule 12.1 to deprive the District Court of jurisdiction under HRS § 604-5(d).
2. Whether the District Court erred by entering a judgment and writ of possession after Medeiros raised a claim that title to the real property was in issue.

Disposition

vacated