Hawaii Revised Statutes

Haw. Rev. Stat. § 657-33 (2026)

Action accrues when

✓ current as of July 2026

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§657-33 Action accrues when. In the construction of this part, the right to make an entry or commence an action shall be deemed to have first accrued at the following times:

(1) When any person is disseised, that person's right of entry or action shall be deemed to have accrued at the time of the disseisin;

(2) When any person claims as heir or devisee of one who died seised, that person's right shall be deemed to have accrued at the time of the death, unless there is an estate by the curtesy or in dower, or some other estate intervening after the death of the ancestor or devisor, in which case that person's right shall be deemed to have accrued when the intermediate estate shall expire, or when it would have expired by its own limitation;

(3) Where there is an intermediate estate, and in all other cases, where a party claims in remainder, or reversion, that party's right so far as it is affected by the limitation herein prescribed, shall be deemed to accrue when the intermediate or precedent estate would have expired by its own limitation, notwithstanding any forfeiture thereof, for which that party might have entered at an earlier time;

(4) Paragraph (3) shall not prevent any person from entering, when entitled to do so, by reason of any forfeiture or breach of condition, but if a person claims under such a title, that person's right shall be deemed to have accrued when the forfeiture was incurred or condition broken; and

(5) In the cases not otherwise specially provided for, the right shall be deemed to have accrued when the claimant, or the person under whom the claimant claims, first became entitled to the possession of the premises under the title upon which the entry or action is founded. [L 1870, c 22, §3; RL 1925, §2659; RL 1935, §3930; RL 1945, §10441; RL 1955, §241-32; HRS §657-33; am L 2016, c 55, §35]

Case Notes

Remaindermen and life tenants. 18 H. 625 (1908), aff'd, 222 U.S. 285 (1911).

Entry means entry by claimant personally as well as entry through another. 54 H. 489, 510 P.2d 93 (1973).

Cited: 19 H. 602, 605 (1909); 19 H. 681, 683 (1909).

Cited: 133 H. 425 (App.), 329 P.3d 330 (2014).

Notes of Decisions

Cited in 3 cases, 1973–2014 · leading case: In Re the Determination & Declaration of the Heirs of Keamo, 650 P.2d 1365 (Haw. App. 1982).

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In Re the Determination & Declaration of the Heirs of Keamo, 650 P.2d 1365 (Haw. App. 1982). · cites it 6× “12 HRS § 657-33 reads in part as follows: In the construction of this part, the right to make an entry or commence an action, shall be deemed to have first accrued at the following times: (1) When any person is disseised, his right of entry or action shall be deemed to have…”

Malulani Grp., Ltd. v. Kaupo Ranch, Ltd., 329 P.3d 330 (Haw. App. 2014). · cites it 7× “HRS § 657-33 (1993) sets forth when an action accrues under HRS § 657-31 and further illustrates that implied easements are not subject to the statute of limitations in HRS § 657-31.”

McAulton v. Smart, 510 P.2d 93 (Haw. 1973). · cites it 4× “22, § 3 (2) is compiled in HRS §657-33 (2), without any change. 2 Laws of 1870, c.”

— Haw. Rev. Stat. § 657-33(2) — 1 case

In Re the Determination & Declaration of the Heirs of Keamo, 650 P.2d 1365 (Haw. App. 1982). “12 HRS § 657-33 reads in part as follows: In the construction of this part, the right to make an entry or commence an action, shall be deemed to have first accrued at the following times: (1) When any person is disseised, his right of entry or action shall be deemed to have…”

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