[§134-24] Place to keep unloaded firearms
other than pistols and revolvers; penalty. (a) Except as provided in
section 134-5, all firearms shall be confined to the possessor's place of
business, residence, or sojourn; provided that it shall be lawful to carry
unloaded firearms in an enclosed container from the place of purchase to the
purchaser's place of business, residence, or sojourn, or between these places
upon change of place of business, residence, or sojourn, or between these
places and the following:
(1) A place of repair;
(2) A target range;
(3) A licensed dealer's place of business;
(4) An organized, scheduled firearms show or exhibit;
(5) A place of formal hunter or firearm use training
or instruction; or
(6) A police station.
"Enclosed container" means a rigidly
constructed receptacle, or a commercially manufactured gun case, or the
equivalent thereof that completely encloses the firearm.
(b) Any person violating this section by
carrying or possessing an unloaded firearm other than a pistol or revolver
shall be guilty of a class C felony. [L 2006, c 66, pt of §1]
Case Notes
Discussed: 911 F. Supp. 2d 972 (2012).
Notes of Decisions
Cited in
6
cases (
3 in the last 5 years), 2018–2025 · leading case:
State v. Souza., 420 P.3d 321 (Haw. 2018).
State v. Souza., 420 P.3d 321 (Haw. 2018).
· cites it 3× “HRS § 134-24 (2011) provides in relevant part as follows: (a) Except as provided in section 134-5, all firearms shall be confined to the possessor's place of business, residence, or sojourn; provided that it shall be lawful to carry unloaded firearms in an enclosed container…”
State v. Medeiros., 454 P.3d 1069 (Haw. 2019).
· cites it 2× “The State charged Medeiros by Felony Information and Non-Felony Complaint with the following four counts: Count I: Place to Keep Unloaded Firearms Other Than Pistol and Revolvers, a class C felony, in violation of HRS § 134-24(a) (2011); Count II: Place to Keep Ammunition, a…”
State v. Duong (Haw. App. 2022).
· cites it 5× “NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER counts: (1) Place to Keep Unloaded Firearms Other Than Pistols and Revolvers in violation of Hawaii Revised Statutes (HRS) § 134-24(a) (2011);2 (2) Place to Keep Pistol or Revolver in violation of HRS § 134-25(a)…”
State v. Oili, 549 P.3d 343 (Haw. App. 2024).
· cites it 2× “Oili was charged in the 2011 case with: (1) Terroristic Threatening in the First Degree, in violation of Hawaii Revised Statutes (HRS) §§ 707-715(1) and 707-716(1)(e); (2) Burglary in the First Degree, in violation of HRS § 708- 810(1)(c); (3) Place to Keep Unloaded Firearms…”
Rodrigues v. Cnty. of Hawaii (D. Haw. 2019).
· cites it 2× “HRS § 134-23 and HRS § 134-24 are virtually identical in governing firearms other than pistols and revolvers, except that the former applies to loaded firearms and the latter to unloaded firearms.”
State v. Bibbs. (Haw. App. 2025).
· cites it 2× “ount 1, Terroristic Threatening in the First Degree, in violation of HRS § 707-716(1)(e); (2) Count 2, Unlawful Possession of Firearm, in violation of HRS § 134-4(b); 4 FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER (3) Count 3, Unlawful Possession of Firearm, in…”
— Haw. Rev. Stat. § 134-24(a) — 3 cases
State v. Medeiros., 454 P.3d 1069 (Haw. 2019).
“The State charged Medeiros by Felony Information and Non-Felony Complaint with the following four counts: Count I: Place to Keep Unloaded Firearms Other Than Pistol and Revolvers, a class C felony, in violation of HRS § 134-24(a) (2011); Count II: Place to Keep Ammunition, a…”
State v. Duong (Haw. App. 2022).
“NOT FOR PUBLICATION IN WEST'S HAWAI#I REPORTS AND PACIFIC REPORTER counts: (1) Place to Keep Unloaded Firearms Other Than Pistols and Revolvers in violation of Hawaii Revised Statutes (HRS) § 134-24(a) (2011);2 (2) Place to Keep Pistol or Revolver in violation of HRS § 134-25(a)…”
State v. Oili, 549 P.3d 343 (Haw. App. 2024).
“Oili was charged in the 2011 case with: (1) Terroristic Threatening in the First Degree, in violation of Hawaii Revised Statutes (HRS) §§ 707-715(1) and 707-716(1)(e); (2) Burglary in the First Degree, in violation of HRS § 708- 810(1)(c); (3) Place to Keep Unloaded Firearms…”
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