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Hawaii Revised Statutes

Haw. Rev. Stat. § 520-1 (2026)

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✓ current as of July 2026
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     [§520-1]  Purpose.  The purpose of this chapter is to encourage owners of land to make land and water areas available to the public for recreational purposes by limiting their liability toward persons entering thereon for such purposes. [L 1969, c 186, §1]

 

Case Notes

 

  Cited:  557 F.2d 1308 (1977); 916 F. Supp. 1511 (1996).

 

 

Notes of Decisions
Cited in 16 cases, 1986–2017 · leading case: Thompson v. Kyo-Ya Co., Ltd., 146 P.3d 1049 (Haw. 2006).
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Thompson v. Kyo-Ya Co., Ltd., 146 P.3d 1049 (Haw. 2006). · cites it 12× “520 HRS § 520-1 (1993) states that "[t]he purpose of this chapter is to encourage owners of land to make land and water areas available to the public for recreational purposes by limiting their liability toward persons entering thereon for such purposes.”
Gold Coast Neighborhood Ass'n v. State., 403 P.3d 214 (Haw. 2017). · cites it 4× “” HRS § 520-1 (2006). To accomplish this purpose, HRS chapter 520 shields from liability 44 ***FOR PUBLICATION IN WEST’S HAWAIʻI REPORTS AND PACIFIC REPORTER*** private property owners who allow the public to use their land for recreational purposes.”
Crichfield v. Grand Wailea Co., 6 P.3d 349 (Haw. 2000). · cites it 3× “” HRS § 520-1 (1993). HRUS defines a number of key terms: “Charge” means the admission price or fee asked in return for invitation or permission to enter or go upon the land.”
Lonergan v. May, 53 S.W.3d 122 (Mo. Ct. App. 2001). · cites it 2× “…§§ 5901-5907 (1991); Fla. Stat. Ann. § 375.251 (West 2000); Ga.Code Ann. § 27-3-1 (1997), §§ 51-3-20 to -26 (2000); Haw.Rev.Stat. Ann. §§ 520-1 to -8 (Michie 1993 & Supp. 1997); Idaho Code § 36-1604 (Michie 1994 & Supp. 2000); 745 Ill. Comp. Stat. Ann. 65/1 to 65/7 (West…”
Collard v. United States, 691 F. Supp. 256 (D. Haw. 1988). · cites it 6× “The United States contends that the Hawaii Recreational Use Statute (Haw.Rev.Stat. §§ 520-1, et seq.) which encourages land owners to make land and water available to the public for recreational purposes by limiting their liability precludes the United States from liability…”
Conway v. Town of Wilton, 680 A.2d 242 (Conn. 1996). “ts propriety, we note that §§ 52-557j *674 and 52-557g serve different purposes: § 52-557g offers immunity as an incentive for private landowners to open up their land to free public use, while the purpose of § 52-557j is to immunize landowners from liability to snowmobilers…”
Frances Howard v. United States of Am. Us Sailing Ass'n, Inc. Waikiki Yacht Club, a Hawaii Corp. Guy S. Fleming, 181 F.3d 1064 (9th Cir. 1999). · cites it 2× “2 After a bench trial, the district court granted judgment in favor of the Government on Howard’s claims, concluding that the Government was immune from negligence liability under the Hawaii Recreational Use Statute (“HRUS”), Haw.”
Application of Banning, 832 P.2d 724 (Haw. 1992). · cites it 2× “HRS § 520-4 specifically provides that the owner’s liability is limited, with a few exceptions, where he “either directly or indirectly invites or permits without charge any person to use such property for recreational purposes.”
Stout v. United States, 696 F. Supp. 538 (D. Haw. 1987). · cites it 2× “Plaintiff Cynthia Stout, as guardian ad litem for Plaintiff Michael Miller, has not stated nor can she prove a claim upon which relief can be granted under the Federal Tort Claims Act because the Hawaii Recreational Use Statute (HRS §§ 520-1 et seq.) precludes defendant’s…”
Viess v. Sea Enter. Corp., 634 F. Supp. 226 (D. Haw. 1986). · cites it 2× “§ 520-1. “Recreational purpose” is defined to include, without limitation, ".”
Wemple ex rel. Dang v. Dahman, 72 P.3d 499 (Haw. App. 2002). · cites it 2× “” HRS § 520-1 (1993). At the time this lawsuit was filed, the HRUS limited the liability of an owner of land “who either directly or indirectly invitefd] or permitted] without charge any, person to use the property for recreational purposes].”
David L. Klepper v. City of Milford, Kansas, & David L. Klepper v. United States of Am., & Third Party & City of Milford, Kansas, Third Party, 825 F.2d 1440 (3rd Cir. 1987). “, Haw. Rev.Stat. §§ 520-1 to 520-8 (1985). In other states, notably California and Wisconsin, state courts at various levels have concluded that the state and its political subdivisions are not covered under the recreational use statutes of those states.”
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