abuse of process claim (Hawaii) · Go Syfert
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abuse of process claim in Hawaii

7 Hawaii opinions name it 2 courts 1990–2024 2 in the last five years

The cases below were cited by Hawaii courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (3)

CaseFollowedCited
Young v. Allstate Insurance Co.green
haw · 2008 · cited in 5 Hawaii opinions naming this issue, 2009–2024
2 sentences

2024Harder argued that the improper willful act was "the use of the process to silence [her] questions and requests for accommodation regarding the installation of the Speakers." (Emphasis added.) But "in order to establish an abuse of process claim, the plaintiff must prove a 'willful act' distinct from the use of process per se." Id. at 416, 198 P.3d at 679 (italics added).

2024The court declined to follow case law from other jurisdictions holding that using process itself is the requisite willful act, and held: "in order to establish an abuse of process claim, the plaintiff must prove 16 NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER a 'willful act' distinct from the use of process per se." Id. at 416, 198 P.3d at 679 (emphasis added).

45
Kollodge v. Stategreen
alaska · 1988 · cited in 1 Hawaii opinions naming this issue, 2008–2008
1 sentence

2008See Kollodge v. State, 757 P.2d 1024, 1027-28 (Alaska 1988) (observing that the only act of the defendant's that the plaintiffs had alleged in their abuse of process claim was the filing of the complaint *679 with an improper purpose); Oren Royal Oaks Venture v. Greenberg, Bernhard, Weiss & Karma, Inc., 42 Cal.3d 1157 , 232 Cal.Rptr. 567 , 728 P.2d 1202, 1210 (1986) (explaining that the gist of the plaintiff's abuse of process claim was that the defendants improperly instituted a proceeding against the plaintiff).

11
Oren Royal Oaks Venture v. Greenberg, Bernard, Weiss & Karma Inc.green
cal · 1986 · cited in 1 Hawaii opinions naming this issue, 2008–2008
2 sentences

2008See Kollodge v. State, 757 P.2d 1024, 1027-28 (Alaska 1988) (observing that the only act of the defendant's that the plaintiffs had alleged in their abuse of process claim was the filing of the complaint *679 with an improper purpose); Oren Royal Oaks Venture v. Greenberg, Bernhard, Weiss & Karma, Inc., 42 Cal.3d 1157 , 232 Cal.Rptr. 567 , 728 P.2d 1202, 1210 (1986) (explaining that the gist of the plaintiff's abuse of process claim was that the defendants improperly instituted a proceeding against the plaintiff).

2008See Kollodge v. State, 757 P.2d 1024, 1027-28 (Alaska 1988) (observing that the only act of the defendant's that the plaintiffs had alleged in their abuse of process claim was the filing of the complaint *679 with an improper purpose); Oren Royal Oaks Venture v. Greenberg, Bernhard, Weiss & Karma, Inc., 42 Cal.3d 1157 , 232 Cal.Rptr. 567 , 728 P.2d 1202, 1210 (1986) (explaining that the gist of the plaintiff's abuse of process claim was that the defendants improperly instituted a proceeding against the plaintiff).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Hawaii. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Chung v. McCabe Hamilton & Renny Co., Ltd. green
haw · 2006
2 sentences

2018Co., 119 Hawai'i 403 , 413-14, 198 P.3d 666 , 676-77 (2008) (even if an "ulterior purpose" is sufficiently alleged, an abuse of process claim requires a "wilful act" in the use of the process which is not proper in the regular conduct of the proceeding (quoting Chung v. McCabe Hamilton & Renny Co., 109 Hawai'i 520 , 529, 128 P.3d 833 , 842 (2006) ) ); Hawkins v. Webster, 337 S.E.2d 682 , 685 (N.C.

2018Co., 119 Hawai'i 403 , 413-14, 198 P.3d 666 , 676-77 (2008) (even if an "ulterior purpose" is sufficiently alleged, an abuse of process claim requires a "wilful act" in the use of the process which is not proper in the regular conduct of the proceeding (quoting Chung v. McCabe Hamilton & Renny Co., 109 Hawai'i 520 , 529, 128 P.3d 833 , 842 (2006) ) ); Hawkins v. Webster, 337 S.E.2d 682 , 685 (N.C.

22008–2018
Isobe v. Sakatani green
hawapp · 2012
1 sentence

2024Id. at 386, 279 P.3d at 51 .

12024–2024
Hawkins v. Webster green
ncctapp · 1985
1 sentence

2018Co., 119 Hawai'i 403 , 413-14, 198 P.3d 666 , 676-77 (2008) (even if an "ulterior purpose" is sufficiently alleged, an abuse of process claim requires a "wilful act" in the use of the process which is not proper in the regular conduct of the proceeding (quoting Chung v. McCabe Hamilton & Renny Co., 109 Hawai'i 520 , 529, 128 P.3d 833 , 842 (2006) ) ); Hawkins v. Webster, 337 S.E.2d 682 , 685 (N.C.

12018–2018
Urez Corp. v. Superior Court green
calctapp · 1987
2 sentences

2012In S. Utsunomiya, the court relied on Urez Corp. v. Superior Court, 190 Cal.App.3d 1141 , 235 Cal.Rptr. 837 (1987) and quoted favorably from Urez that “allegations of equitable remedies, even if colorable, will not support a lis pendens if, ultimately, those allegations act only as a collateral means to collect money damages." 75 Haw. at 511 , 866 P.2d at 966 .

2012In S. Utsunomiya, the court relied on Urez Corp. v. Superior Court, 190 Cal.App.3d 1141 , 235 Cal.Rptr. 837 (1987) and quoted favorably from Urez that “allegations of equitable remedies, even if colorable, will not support a lis pendens if, ultimately, those allegations act only as a collateral means to collect money damages." 75 Haw. at 511 , 866 P.2d at 966 .

12012–2012
S. Utsunomiya Enterprises, Inc. v. Moomuku Country Club green
haw · 1994
2 sentences

2012In S. Utsunomiya, the court relied on Urez Corp. v. Superior Court, 190 Cal.App.3d 1141 , 235 Cal.Rptr. 837 (1987) and quoted favorably from Urez that “allegations of equitable remedies, even if colorable, will not support a lis pendens if, ultimately, those allegations act only as a collateral means to collect money damages." 75 Haw. at 511 , 866 P.2d at 966 .

2012In S. Utsunomiya, the court relied on Urez Corp. v. Superior Court, 190 Cal.App.3d 1141 , 235 Cal.Rptr. 837 (1987) and quoted favorably from Urez that “allegations of equitable remedies, even if colorable, will not support a lis pendens if, ultimately, those allegations act only as a collateral means to collect money damages." 75 Haw. at 511 , 866 P.2d at 966 .

12012–2012
Wong v. Panis green
hawapp · 1989
2 sentences

2008Accordingly, we conclude that the allegations sufficiently state that the Defendants employed process primarily for an ulterior purpose. 2. "a wilful act in the use of process which is not proper in the regular conduct of the proceeding" We next reach the second element of the abuse of process claim: whether the defendant committed "`a wilful act in the use of the process which is not proper in the regular conduct of the proceeding.'" Chung , 109 Hawai`i at 529, 128 P.3d at 842 (quoting Wong, 7 Haw.App. at 420 , 772 P.2d at 699-700 ).

2008Accordingly, we conclude that the allegations sufficiently state that the Defendants employed process primarily for an ulterior purpose. 2. "a wilful act in the use of process which is not proper in the regular conduct of the proceeding" We next reach the second element of the abuse of process claim: whether the defendant committed "`a wilful act in the use of the process which is not proper in the regular conduct of the proceeding.'" Chung , 109 Hawai`i at 529, 128 P.3d at 842 (quoting Wong, 7 Haw.App. at 420 , 772 P.2d at 699-700 ).

12008–2008
Myers v. Cohen green
haw · 1984
2 sentences

1990App. 232 , 687 P.2d 6 , rev’d on other grounds, 67 Haw. 389 , 688 P.2d 1145 (1984), we stated that it is the purpose for which the process is used rather than the nature of the process that creates the abuse of process claim.

1990App. 232 , 687 P.2d 6 , rev’d on other grounds, 67 Haw. 389 , 688 P.2d 1145 (1984), we stated that it is the purpose for which the process is used rather than the nature of the process that creates the abuse of process claim.

11990–1990
Myers v. Cohen green
hawapp · 1984
1 sentence

1990App. 232 , 687 P.2d 6 , rev’d on other grounds, 67 Haw. 389 , 688 P.2d 1145 (1984), we stated that it is the purpose for which the process is used rather than the nature of the process that creates the abuse of process claim.

11990–1990

Where else courts name it

OH 53 (1994–2025) MA 51 (1986–2026) CA 44 (1986–2026) NY 25 (1986–2026) CT 22 (1991–2025) PA 20 (2001–2025) CO 20 (1986–2026) TX 19 (1993–2025) SC 17 (1994–2026) NM 17 (1987–2024) NV 16 (1986–2022) IN 16 (1994–2025) AL 15 (1981–2024) ME 15 (1984–2023) IA 14 (1982–2021) NC 13 (1986–2025) MO 12 (1993–2022) MT 12 (2000–2024) MS 10 (1999–2025) WA 10 (2008–2026) AZ 10 (1982–2024) RI 8 (1989–2010) MI 8 (1984–2024) LA 8 (1993–2024) AR 8 (1993–2021) VA 8 (1989–2021) KY 7 (2013–2024) HI 7 (1990–2024) UT 7 (2004–2025) IL 7 (1996–2023) KS 6 (1988–2021) FL 6 (1984–2025) NJ 6 (1992–2026) WI 5 (1979–2026) AK 5 (1988–2025) TN 5 (2000–2020) DE 4 (2014–2024) ND 4 (2015–2020) OR 3 (1986–2023) OK 3 (2000–2020) SD 3 (1991–2022) NH 3 (1995–2019) MN 2 (1979–2014) NE 2 (1998–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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