Justia Hawaii Supreme Court Opinion Summaries

After a couple ended their relationship, they continued to share custody of a dog they had jointly acquired. This shared arrangement lasted for two years, but in early 2026, one party refused to return the dog as scheduled. The other party then filed a claim in the small claims division of the District Court of the Second Circuit in Hawai‘i, seeking the return of the dog or, alternatively, monetary compensation. The claimant argued she co-owned the dog, had paid for its care, and that money damages would be inadequate. The defendant asserted he assumed full custody after learning the claimant might leave the island and asked the court to confirm his ownership.The District Court of the Second Circuit’s small claims division conducted a trial and found it equitable to grant legal and physical ownership of the dog to the defendant. The court also ordered the defendant to pay the claimant a sum representing half the value of the dog plus half the veterinary bills. The claimant’s motions to set aside the judgment and for reconsideration or new trial were denied, with the court reasoning that she had chosen the forum and was requesting monetary relief.The Supreme Court of the State of Hawai‘i reviewed the case on a petition for a writ of mandamus, as no appeal is allowed from a small claims judgment. The Supreme Court held that the small claims division lacked subject matter jurisdiction to decide ownership of the dog because its statutory authority is limited to money claims under $5,000, residential security-deposit disputes, and the return of leased or rented property. The claim for ownership of the dog was not within those categories. The Supreme Court granted the writ, vacated the lower court’s ruling, and remanded with instructions to dismiss the case without prejudice. View "Miller v. Collins" on Justia Law