Rivera v. Cataldo., 537 P.3d 1167

The Hawaiian Homes Commission Act created a trust to provide homesteads to Native Hawaiians; the State breached its fiduciary duties and beneficiaries sued (Kalima class action).
In 1991 the legislature waived sovereign immunity and limited recoveries to individual breaches occurring between August 21, 1959 and June 30, 1988 (HRS Chapter 674 framework).
In 2022 the State agreed to a $328 million settlement; the circuit court found 2,515 eligible class members (1,351 living; 1,164 deceased) and approved distribution rules administered by a claims administrator.
The settlement and statute required that claimants have been lease-eligible (age 18) by June 30, 1988; the claims administrator determined Rivera ineligible because he turned 18 on August 21, 1988.
Rivera filed objections, letters, and an appeal request; he also petitioned the Hawaiʻi Supreme Court for a writ of mandamus seeking review of his claim processing. The Supreme Court accepted the petition for expedited resolution due to public importance.
The Court held Rivera ineligible for settlement payment (too young at cutoff), denied mandamus, directed the ICA to dismiss Rivera’s appeal, and remanded to the circuit court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eligibility under the statutory cutoff period	Rivera: he qualifies (claimed first application June 15, 1988; alleges claims administrator error)	State: statute requires claimant to be 18 by June 30, 1988; Rivera turned 18 Aug 21, 1988, so ineligible	Held: Rivera ineligible; turned 18 after June 30, 1988; claims administrator and court correct
Preservation of appellate rights / standing to appeal settlement approval	Rivera: letters and filings preserved an appeal and grounds	State/class: Rivera lacks a legally cognizable claim and thus no right to disrupt finality	Held: Rivera’s pro se filings preserved appellate issues and he had standing to appeal, but he loses on the merits
Use of extraordinary writ / expedited review	Rivera: sought mandamus to compel review of his claim file and processing	State: ordinary appellate process available; mandamus is extraordinary and unwarranted	Held: Writ denied; Court nevertheless exercised supervisory power to resolve promptly given public importance

Kalima v. State, 111 Hawaiʻi 84, 137 P.3d 990 (2006) (describing the State’s breaches of the Hawaiian homes trust)
Kalima v. State, 148 Hawaiʻi 129, 468 P.3d 143 (2020) (continued review of liability and remedial process in the class action)
Erum v. Llego, 147 Hawaiʻi 368, 465 P.3d 815 (2020) (liberal construction of pro se filings to provide routes to relief)
Pub. Access Trails Hawaiʻi v. Haleakala Ranch Co., 153 Hawaiʻi 1, 526 P.3d 526 (2023) (applying the "fair, reasonable, and adequate" standard to class settlements)
Makila Land Co., LLC v. Kapu, 152 Hawaiʻi 112, 522 P.3d 259 (2022) (pro se filings assessed to favor access to relief)
Gannett Pac. Corp. v. Richardson, 59 Haw. 224, 580 P.2d 49 (1978) (extraordinary writs are no substitute for appeal)
Sapienza v. Hayashi, 57 Haw. 289, 554 P.2d 1131 (1976) (circumstances justifying extraordinary relief where delay would cause public harm)
Kaneshiro v. Au, 67 Haw. 442, 690 P.2d 1304 (1984) (supervisory power for matters of public importance)
State v. Moriwake, 65 Haw. 47, 647 P.2d 705 (1982) (judicial power includes advancing justice)