Hawaii Revised Statutes

Haw. Rev. Stat. § 12-31 (2026)

  Selection of party ballot; voting

✓ current as of July 2026
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PART III.  BALLOT SELECTION

 

     §12-31  Selection of party ballot; voting.  No person eligible to vote in any primary or special primary election shall be required to state a party preference or nonpartisanship as a condition of voting.  Each voter shall be issued the primary or special primary ballot for each party and the nonpartisan primary or special primary ballot.  A voter shall be entitled to vote only for candidates of one party or only for nonpartisan candidates.  If the primary or special primary ballot is marked contrary to this paragraph, the ballot shall not be counted.

     In any primary or special primary election in the year 1979 and thereafter, a voter shall be entitled to select and to vote the ballot of any one party or nonpartisan, regardless of which ballot the voter voted in any preceding primary or special primary election. [L 1970, c 26, pt of §2; am L 1973, c 217, §2(i); am L 1974, c 34, §2(c); am L 1979, c 139, §9; gen ch 1985]

 

Cross References

 

  Constitutional provision, see Const. art. II, §4.

 

Case Notes

 

  Where political party did not develop evidence showing that the State's open primary system severely burdened its associational rights, the party's facial challenge failed; among other things, the party provided no evidence showing a "clear and present danger" that adherents of opposing parties determined the party's nominees.  833 F.3d 1119 (2016).

  Where plaintiff claimed provisions requiring an open primary were facially unconstitutional because allowing voters to associate anonymously with a political party violated a party's First Amendment right of free association: (1) plaintiff's purely facial challenge to the open primary failed; and (2) the court could not assess whether plaintiff's associational rights were burdened without considering evidence as to the extent, if any, of that burden.  982 F. Supp. 2d 1166 (2013).

  Selection of a party's ballot does not automatically make voter a party member.  56 H. 519, 542 P.2d 1272.

 

 

Notes of Decisions
Cited in 14 cases (4 in the last 5 years), 1975–2024 · leading case: Burdick v. Takushi, 504 U.S. 428 (1992).
Burdick v. Takushi, 504 U.S. 428 (1992). · cites it 2× “See Haw. Rev. Stat. § 12-31 (1985). The State provides three mechanisms through which a voter's candidate-of-choice may appear on the primary ballot.”
Tashjian v. Repub. Party of Connecticut, 479 U.S. 208 (1986). · cites it 2× “Haw. Rev. Stat. § 12-31 (Supp. 1984); Idaho Code §§ 34-402 , 34-404, 34-904 (Supp.”
Hustace v. Doi, 588 P.2d 915 (Haw. 1978). · cites it 6× “HRS § 12-31. [1] Thus a nonpartisan candidate may seek votes only from voters who are designated nonpartisan or have not voted in a previous primary or have been freed from their previous affiliation by the disqualification of their party or by reregistration.”
Democratic Party v. Nago, 982 F. Supp. 2d 1166 (D. Haw. 2013). · cites it 4× “As amended in 1970, HRS § 12-31 provided in pertinent part: “No person shall be entitled to vote at a primary or special primary election who shall refuse to state his party preference or nonpartisanship to the precinct officials, unless he wishes to vote only for the board of…”
Democratic Party of Hawaii v. Scott Nago, 833 F.3d 1119 (9th Cir. 2016). “” Haw. Rev. Stat. § 12-31 . Thus, voters must commit to one party’s slate prior to voting; they may not choose a Republican nominee for one state office and a Democratic nominee for a different state office.”
Miller v. Cunningham, 512 F.3d 98 (4th Cir. 2007). · cites it 2× “, Haw.Rev.Stat. § 12-31; Idaho Code §§ 34-402 , 34-404, 34-904; Mich.”
Dicks v. State, 557 P.3d 831 (Haw. 2024). · cites it 6× “Next, as to HRS § 12-31, it appears Plaintiff is claiming that the primary ballot violates that statute by requiring a person to identify a party preference before voting.”
Int'l Bhd. of Painters & Allied Trades, Drywall Tapers, Finishers & Allied Workers Local Union 1944 v. Befitel, 88 P.3d 647 (Haw. 2004). “HAR Rule 12—30—(6)(2)(J) and (S) state: An apprenticeship program shall be eligible for registration by the department if it conforms to the following standards: (2) The program standards contain the equal opportunity pledge prescribed in section 12-31—3(b), Administrative…”
Washington State Repub. Party v. Logan, 377 F. Supp. 2d 907 (W.D. Wash. 2005). “§ 21-2-224 ; Haw.Rev.Stat. § 12-31; Idaho Code §§ 34-402 , 34-404, 34-904; Mich.”
Mississippi State Democratic Party v. Barbour, 491 F. Supp. 2d 641 (N.D. Miss. 2007). “The Nine states that have classic “open” primaries with no party registration include: Hawaii, Haw.Rev.Stat. § 12-31; Idaho, Idaho Code §§ 34-402 , 34-404, 34-904; Michigan, Mich.”
Malish v. Nago (Haw. 2022). · cites it 4× “In connection with their request for a declaratory judgment, Plaintiffs seek a declaration that the voting instructions on the 2022 primary election ballot violate article II, section 4 of the Hawaiʻi Constitution and HRS § 12-31 (2009). The disputed instruction says: “You MUST…”
Dicks v. State of Hawaii Off. of Elections (D. Haw. 2022). · cites it 2× “They do not articulate specific claims but assert that the primary election ballot violates HRS §§ 12-21 and 12-31, and that improper votes shall not be counted pursuant to HRS § 12-31. Compl. at 4. Claiming that federal question is the basis for subject matter jurisdiction,…”
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