Hawaii Revised Statutes

Haw. Rev. Stat. § 286-25 (2026)

  Operation of a vehicle or moped without a certificate of inspection

✓ current as of July 2026
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     §286-25  Operation of a vehicle or moped without a certificate of inspection.  Whoever operates, permits the operation of, causes to be operated, or parks any vehicle or moped on a public highway without a current official certificate of inspection, issued under section 286-26, shall be fined not more than $100. [L 1967, c 214, pt of §2; HRS §286-25; am L 1972, c 18, §1; am L 1974, c 106, §1; am L 1993, c 214, §3; am L 2016, c 200, §10]

 

Case Notes

 

  Statute applied to defendant, where defendant argued that traffic statutes involved only applied to businesses and state vehicles; statute did not violate defendant’s freedom of movement.  77 H. 222 (App.), 883 P.2d 644 (1994).

  It is within the power of the legislature to motivate compliance with safety inspection and liability insurance laws by imposing the penalty specified in this section; because the offense of "expired safety sticker" is a civil traffic infraction and not a criminal offense, the district court improperly found motorist "guilty".  107 H. 508 (App.), 115 P.3d 687 (2005).

 

 

Notes of Decisions
Cited in 20 cases (2 in the last 5 years), 1983–2025 · leading case: State v. Cummings, 63 P.3d 1109 (Haw. 2003).
State v. Cummings, 63 P.3d 1109 (Haw. 2003). · cites it 8× “1998), and operation of a motor vehicle without a certificate of inspection, in violation of HRS § 286-25 (1993). Cummings urges this court to reverse his DUI conviction and sentence on the bases that the district court erred: (1) in denying his oral motion to dismiss the DUI…”
State v. Rees, 115 P.3d 687 (Haw. App. 2005). · cites it 16× “On November 14, 2003, a police officer cited Rees for violating HRS § 286-25 (1993) (operation of a vehicle without a current certificate of inspection) while driving a 1988 Toyota.”
State v. Garcia, 29 P.3d 919 (Haw. 2001). · cites it 4× “Effective January 1, 2002, Part XIV of HRS chapter 286, comprising of HRS §§ 286-251 to -266, will be repealed.”
State v. Fergerstrom, 101 P.3d 652 (Haw. App. 2004). · cites it 4× “THE COMPLAINT The complaint filed on May 21, 2002 by the Plaintiff-Appellee State of Hawaii (the *45 State) charged that, on February 9, 2002, Fergerstrom violated the following laws: Count I: Driving Without a License, Hawaii Revised Statutes (HRS) § 286-102(a) (1993); 1 Count…”
State v. French, 883 P.2d 644 (Haw. App. 1994). · cites it 6× “6 (1985) (Count II), “without a current official certificate of inspection” in violation of HRS § 286-25 (1985) (Count III), and “without first being .”
State v. Nishi, 852 P.2d 476 (Haw. App. 1993). · cites it 4× “Pamphlet); 2 and (3) operating a vehicle without a certificate of inspection (No Safety Check) in violation of HRS § 286-25 (1985). 3 After finding that the No No-Fault Insurance violation was a second offense, the district court imposed an enhanced sentence of a $3,000 fine on…”
State v. Young, 109 P.3d 677 (Haw. 2005). · cites it 4× “5, see supra note 2; (3) non-compliance with speed limit prohibited (Count III), in violation of HRS § 291C-102 (1993); and (4) operation of a vehicle without a certificate of inspection (Count IV), in violation of HRS § 286-25 (1993). The indictment alleged that Young committed…”
State v. Langdon., 472 P.3d 31 (Haw. App. 2020). · cites it 27× “On appeal, 2 HRS § 286-25 provides: §286-25 Operation of a vehicle or moped without a certificate of inspection.”
State v. Shamp, 949 P.2d 171 (Haw. App. 1997). · cites it 3× “We affirm the court’s convictions of Defendant in regards to her violations of HRS § 286-25 (1993) and HRS § 249-11 (1993).”
State v. Kelekolio, 14 P.3d 364 (Haw. App. 2000). · cites it 2× “A few examples of sections in HRS chapter 286 that specifically restrict their applicability to the operation of a vehicle on a "highway” or "public highway” include: HRS § 286-25 (1993) ("[wjhoever operates, permits the operation of, causes to be operated, or parks any vehicle…”
State v. Apuna, 657 P.2d 1062 (Haw. App. 1983). · cites it 7× “1982) 1 for which she was fined $100, and (2) operating a vehicle on a public highway without a current official certificate of inspection in violation of HRS § 286-25 (1976) 2 for which she was fined $15.”
In the Interest of Doe, 844 P.2d 679 (Haw. App. 1992). · cites it 2× “FACTS In the early morning hours of July 20,1991, Doe was arrested and thereafter charged with (1) DUI; (2) driving through a red light in violation of HRS § 291C-32(a)(3A) (1985); and (3) driving with an expired safety sticker in violation of HRS § 286-25 (1985). Doe filed a…”
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