Haw. Rev. Stat. » Haw. Rev. Stat. / Chapter 107
Hawaii Revised Statutes

Haw. Rev. Stat. § 107-10 (2026)

  Acquiring of real property; prior approval. 

✓ current as of July 2026
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     §107-10  Acquiring of real property; prior approval.  No real property or any right, title, or interest therein shall be acquired by agreement, purchase, gift, devise, eminent domain, or otherwise, for any purpose, by the State or any department, agency, board, commission, or officer thereof, without the prior approval of the attorney general as to form, exceptions, and reservations.  As to property acquired by the University of Hawaii, the attorney general may delegate to the University general counsel the authority to approve as to form, exceptions, and reservations.  In cases involving acquisitions by the University of Hawaii of interests in real property that do not require legislative appropriations, the general counsel for the University of Hawaii may give approval as to form, exceptions, and reservations. [L 1959, c 135, §1; Supp, §7-43; HRS §107-10; am L 2001, c 243, §5]

 

Attorney General Opinions

 

  The State already holds an inchoate right to land that may pass to it by erosion or sea level rise.  Ripening of that inchoate right is not "acquiring" or "acquisition" of real property under this section, §26-7, or §171-30.  Accordingly, the attorney general does not have to review the ownership change and does not have to review or approve "documents relating to" the ownership.  Att. Gen. Op. 17-1.

 

Case Notes

 

  Circuit court correctly determined that the State obtained an easement over and across seawall pursuant to the common law doctrine of implied dedication because this section and §§26-7, 171-30, 264-1(c)(1), and 520-7 do not "imperatively require" abrogation of common law implied dedication, nor do they evince an express legislative intent to do so.  140 H. 437, 403 P.3d 214 (2017).

 

 

Notes of Decisions
Cited in 2 cases, 2015–2017 · leading case: Gold Coast Neighborhood Ass'n v. State., 403 P.3d 214 (Haw. 2017).
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Gold Coast Neighborhood Ass'n v. State., 403 P.3d 214 (Haw. 2017). · cites it 16× “16 Although the State raised arguments based on HRS §§ 171-30, 26-7, and 520-7 before the circuit court, it only raised HRS § 107-10 in support of its argument before the ICA by letter to the appellate clerk dated May 7, 2015, after submission of its Opening Brief.”
Gold Coast Neighborhood Ass'n v. State, 361 P.3d 1243 (Haw. App. 2015). · cites it 11× “Because the State’s argument that neither an easement by implied dedication nor a public highway by surrender may be established without the State’s consent under HRS § 171-30, HRS § 26-7, and HRS § 107-10 was raised for the first time on appeal, whether to address the argument…”
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