enforceable claim in Hawaii

2025However, in construing HRS § 657-5, this court has previously held that the statute of limitations for enforcing a judgment does not begin to run until “the cause of action—the judgment that creates the enforceable claim or right—comes into existence as an enforceable claim or right.” Estate of Roxas v. Marcos, 121 Hawai‘i 59, 69, 214 P.3d 598, 608 (2009) (internal quotation marks omitted).

2025DISCUSSION A. 2020 Appeal POE 1: William argues that Barbara's 2008 motion to enforce was barred by the ten-year statute of limitations in HRS § 657-5. 12 William contends the 1990 Kimura Order Dividing Benefits and 1992 Kimura Order Denying Relief became enforceable when William's HIPD contributions ended, i.e. when he stopped working for HIPD in 1992 (excluding his subsequent working service at the Prosecutor's Office), "because no other source of contribution was stated or allowed by Judge Kimura's Order." "[T]he statute of limitations for extending a judgment begins to run when the cause o

2007(Quoting Teller v. Teller, 99 Hawai'i 101, 110 , 53 P.3d 240, 249 (2002) (quoting In re Akana, 42 Haw. 415, 444 (1958) (Stainback, J., dissenting) (“The dictionary gives the following definition for the word ‘accrue’: ‘To come into existence as an enforceable claim; to vest as a right; as, a cause of action has accrued when the right to sue has become vested.’ ”)); Stubbs v. Miss.

2002Determining when an idea becomes a trade secret with present or future value requires an inquiry into when the right in the trade secret “vests” or “accrues.” This court has defined the term “accrued” as “[t]o come into existence as an enforceable claim; to vest as a right; as, a cause of action has accrued when the right to sue has become vested.” Akana v. Damon, 42 Haw. 415, 415 (Hawai’i Terr.1958).

2021See, e.g., Schwab, 58 Haw. at 33-34 , 564 P.2d at 140-41 (applying the germaneness standard to the single subject requirement); Kua, 22 Haw. at 313 (applying the germaneness standard to the single subject requirement); Territory v. Dondero, 21 Haw. 19, 25 (1912) (considering whether the title of a city ordinance violated the city charter’s subject-in-title provision and applying a germaneness standard).

2021See, e.g., Schwab, 58 Haw. at 33-34 , 564 P.2d at 140-41 (applying the germaneness standard to the single subject requirement); Kua, 22 Haw. at 313 (applying the germaneness standard to the single subject requirement); Territory v. Dondero, 21 Haw. 19, 25 (1912) (considering whether the title of a city ordinance violated the city charter’s subject-in-title provision and applying a germaneness standard).

2021See, e.g., Schwab, 58 Haw. at 33-34 , 564 P.2d at 140-41 (applying the germaneness standard to the single subject requirement); Kua, 22 Haw. at 313 (applying the germaneness standard to the single subject requirement); Territory v. Dondero, 21 Haw. 19, 25 (1912) (considering whether the title of a city ordinance violated the city charter’s subject-in-title provision and applying a germaneness standard).

2021See, e.g., Schwab, 58 Haw. at 33-34 , 564 P.2d at 140-41 (applying the germaneness standard to the single subject requirement); Kua, 22 Haw. at 313 (applying the germaneness standard to the single subject requirement); Territory v. Dondero, 21 Haw. 19, 25 (1912) (considering whether the title of a city ordinance violated the city charter’s subject-in-title provision and applying a germaneness standard).

2007(Quoting Teller v. Teller, 99 Hawai'i 101, 110 , 53 P.3d 240, 249 (2002) (quoting In re Akana, 42 Haw. 415, 444 (1958) (Stainback, J., dissenting) (“The dictionary gives the following definition for the word ‘accrue’: ‘To come into existence as an enforceable claim; to vest as a right; as, a cause of action has accrued when the right to sue has become vested.’ ”)); Stubbs v. Miss.

2007(Quoting Teller v. Teller, 99 Hawai'i 101, 110 , 53 P.3d 240, 249 (2002) (quoting In re Akana, 42 Haw. 415, 444 (1958) (Stainback, J., dissenting) (“The dictionary gives the following definition for the word ‘accrue’: ‘To come into existence as an enforceable claim; to vest as a right; as, a cause of action has accrued when the right to sue has become vested.’ ”)); Stubbs v. Miss.