Hawaii Revised Statutes

Haw. Rev. Stat. § 657-9 (2026)

  Action barred in foreign jurisdiction

✓ current as of July 2026
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     §657-9  Action barred in foreign jurisdiction.  When a cause of action has arisen in any foreign jurisdiction, and by the laws thereof an action thereon cannot there be maintained against a person, by reason of the lapse of time, an action thereon shall not be maintained against the person in this State, except in favor of a domiciled resident thereof, who has held the cause of action from the time it accrued. [CC 1859, §1167; RL 1925, §2646; RL 1935, §3917; RL 1945, §10428; RL 1955, §241-8; HRS §657-9; gen ch 1985]

 

Case Notes

 

  Enforcement of valid and subsisting foreign judgment.  128 F. Supp. 697 (1955).

  Where, pursuant to Philippine case law, relevant Philippine statutes of limitations were tolled as a matter of law, action was brought in this State within the time required under the relevant Philippine statutes of limitations as required by this section.  89 H. 91, 969 P.2d 1209 (1998).

 

 

Notes of Decisions
Cited in 10 cases, 1977–2019 · leading case: Roxas v. Marcos, 969 P.2d 1209 (Haw. 1998).
Roxas v. Marcos, 969 P.2d 1209 (Haw. 1998). · cites it 4× “HRS § 657-9 (1993) provides that [w]hen a cause of action has arisen in any foreign jurisdiction, and by the laws thereof an action thereon cannot there be maintained against a person, by reason of the lapse of time, an action thereon shall not be maintained against the person…”
Gennifer Flowers v. James Carville Hillary Rodham Clinton Little, Brown & Co. George Stephanopoulos, 310 F.3d 1118 (9th Cir. 2002). “Code tit. 4, § 111 (1934), quoted in Ester, supra, at 83 ("one who has been a resident”).”
Small v. Badenhop, 701 P.2d 647 (Haw. 1985). “ct, obligation, or liability, excepting such as are brought upon the judgment or decree of a court; excepting further that actions for the recovery of any debt founded upon any contract, obligation, or liability made pursuant to chapter 577A shall be governed by chapter 577A;…”
Ass'n of Apt. Owners of Royal Aloha v. Certified Mgmt., Inc., 378 P.3d 992 (Haw. App. 2016). “y contract, obligation, or liability, excepting such as are brought upon the judgment or decree of a court; excepting further that actions for the recovery of any debt founded upon any contract, obligation, or liability made pursuant to chapter 577A shall be governed by 577A;…”
Froelich v. Petrelli, 472 F. Supp. 756 (D. Haw. 1979). “§ 657-9; Annot., 149 A.L.R. 1224 (1944); 75 A.”
Allstate Ins. v. Wolcott, 847 F. Supp. 787 (D. Haw. 1994). “ct, obligation, or liability, excepting such as are brought upon the judgment or decree of a court; excepting further that actions for the recovery of any debt founded upon any contract, obligation, or liability made pursuant to chapter 577A shall be governed by Chapter 577A;…”
Mun Seek Pai v. First Hawaiian Bank, 558 P.2d 479 (Haw. 1977). “The following actions shall be commenced within six years next after the cause of action accrued, and not after: (1) Actions for the recovery of any debt founded upon any contract, obligation, or liability, excepting such as are brought upon the judgment or decree of a court;…”
Beecher Ltd. v. Alvarez & Marsal North Am., LLC, 179 P.3d 264 (Haw. App. 2008). · cites it 7× “Prior to April 24, 1996, a creditor seeking to enforce in Hawai`i courts a judgment rendered by a court of record in any foreign jurisdiction was required to bring a separate action upon that judgment, subject to HRS § 657-9 (1993), [5] "within six years next after the cause of…”
Schnute v. PNC Bank, N.A. (D. Haw. 2019). “ct, obligation, or liability, excepting such as are brought upon the judgment or decree of a court; excepting further that actions for the recovery of any debt founded upon any contract, obligation, or liability made pursuant to chapter 577A shall be governed by chapter 577A;…”
Weidenbach v. Koolau Agric. Co., Ltd., 203 P.3d 674 (Haw. App. 2009). “ct, obligation, or liability, excepting such as are brought upon the judgment or decree of a court; excepting further that actions for the recovery of any debt founded upon any contract, obligation, or liability made pursuant to chapter 577A shall be governed by chapter 577A;…”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.