Hawaii Revised Statutes
Haw. Rev. Stat. § 520-6 (2026)
] Persons using land
✓ current as of July 2026
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[§520-6] Persons using land. Nothing in this chapter shall be construed to:
(1) Create a duty of care or ground of liability for injury to persons or property.
(2) Relieve any person using the land of another for recreational purposes from any obligation which the person may have in the absence of this chapter to exercise care in the person's use of such land and in the person's activities thereon, or from the legal consequences of failure to employ such care. [L 1969, c 186, §6; gen ch 1985]
Notes of Decisions
Cited in 9
cases (1 in the last 5 years), 1990–2021 · leading case: Thompson v. Kyo-Ya Co., Ltd., 146 P.3d 1049 (Haw. 2006).
Thompson v. Kyo-Ya Co., Ltd., 146 P.3d 1049 (Haw. 2006). “" [5] HRS § 520-6 in fact emphasizes the duty of the entrant: Nothing in this chapter shall be construed to: (1) Create a duty of care or ground of liability for injury to persons or property.”
Crichfield v. Grand Wailea Co., 6 P.3d 349 (Haw. 2000). “HRS § 520-6 (1993). HRUS also provides that: (a) Except as specifically recognized by or provided in section 520-6, an owner of land who either directly or indirectly invites or permits without charge any person to use the property for recreational purposes does not: (1) Extend…”
Lansdell v. Cnty. of Kauai, 130 P.3d 1054 (Haw. 2006). “) HRS § 520-6 (1993) also describes the duty of care on the part of persons utilizing property of another for recreational purposes.”
Atahan v. Muramoto, 984 P.2d 104 (Haw. App. 1999). “* * * § 520-6 Persons using land. Nothing in this chapter shall be construed to: (1) Create a duty of care or ground of liability for injury to persons or property.”
Palmer v. United States, 742 F. Supp. 1068 (D. Haw. 1990). “The Hawaii Recreational Use Statute, Hawaii Revised Statute section 520-4, provides that “except as specifically recognized by or provided in section 520-6, an owner of land who either directly or indirectly invites or permits without charge any person to use such property for…”
Covington v. United States, 916 F. Supp. 1511 (D. Haw. 1996). “§ 520-3 provides: Except as specifically recognized by or provided in section 520-6, an owner of land owes no duty of care to keep the premises safe for entry or use by others for recreational purposes, or to give any warning of a dangerous condition, use, structure, or activity…”
Brown v. United States, 180 F. Supp. 2d 1132 (D. Haw. 2001). “§ 520-4 limits liability as follows: a) Except as specifically recognized by or provided in section 520-6, an owner of land who either directly or indirectly invites or permits without charge any person to use the properly for recreational purposes does not: (1) Extend any…”
Covington v. United States, 902 F. Supp. 1207 (D. Haw. 1995). “In particular, Chapter 520 of the HRUS limits the duty of land owners as follows: Except as specifically recognized by or provided in section 520-6, an owner of land owes no duty of care to keep the premises safe for entry or use by others for recreational purposes, or to give…”
Jacobs v. Billy Casper Golf, LLC., 500 P.3d 474 (Haw. App. 2021). “In turn, HRS § 520-6 (2006) states: § 520-6 Persons using land.”
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