Keahi v. Agena

Summary

The Hawaiʻi Intermediate Court of Appeals dismissed Kona Wong Kapule’s appeal for lack of appellate jurisdiction. The court held that the circuit court’s oral order denying a motion to quash was not appealable, and that no final judgment, interlocutory appeal authorization, collateral-order exception, or Forgay doctrine supported jurisdiction.

Holdings

1. The oral order was not appealable because a minute order is not an appealable order, and the challenged oral order was not a decision that could be reduced to a final judgment.
2. The order was not independently appealable under the collateral-order or Forgay doctrines.

Questions Presented

1. Whether the Circuit Court's oral order denying Kapule's special appearance and motion to quash was appealable.
2. Whether the Intermediate Court of Appeals had appellate jurisdiction under the final-judgment rule, the interlocutory-appeal statute, or the collateral-order or Forgay doctrines.

Disposition

dismissed