Haw. Rev. Stat. » Haw. Rev. Stat. / Chapter 658A
Hawaii Revised Statutes

Haw. Rev. Stat. § 658A-25 (2026)

] Judgment on award; attorney's fees and litigation expenses

✓ current as of July 2026
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     [§658A-25]  Judgment on award; attorney's fees and litigation expenses.  (a)  Upon granting an order confirming, vacating without directing a rehearing, modifying, or correcting an award, the court shall enter a judgment in conformity therewith.  The judgment may be recorded, docketed, and enforced as any other judgment in a civil action.

     (b)  A court may allow reasonable costs of the motion and subsequent judicial proceedings.

     (c)  On application of a prevailing party to a contested judicial proceeding under section 658A-22, 658A-23, or 658A-24, the court may add reasonable attorney's fees and other reasonable expenses of litigation incurred in a judicial proceeding after the award is made to a judgment confirming, vacating without directing a rehearing, modifying, or correcting an award. [L 2001, c 265, pt of §1]

 

Case Notes

 

  Subsection (a), which enumerates the appeals that may be taken from a court order concerning an arbitration proceeding, does not represent an exclusive list of appealable orders; thus, although not listed in subsection (a), order compelling arbitration was sufficiently final under the collateral order doctrine to be appealable under §641-1.  129 H. 378, 301 P.3d 588 (2013).

  In judicial proceedings to confirm arbitration award, circuit court erred by including in its judgment $4,738.74 in attorney's fees because that amount was not part of the arbitration award of $8,355.49 and was not allowable pursuant to this section despite those fees being characterized as arbitration attorney's fees.  139 H. 445, 393 P.3d 997 (2017).

  In judicial proceedings to confirm arbitration award, circuit court judgment properly included award of $1,692.80 in attorney's fees pursuant to subsection (c).  Although the award was mischaracterized, subsection (c) allows a court to award attorney's fees incurred in judicial proceedings to confirm an arbitration award when a motion to confirm award under §658A-22 is contested.  139 H. 445, 393 P.3d 997 (2017).

  Because judicial review of an arbitration award is confined to the strictest possible limits, and because the arbitrator reasonably interpreted arbitration agreement in fashioning the award, arbitrator did not exceed his authority by awarding attorneys' fees and costs on appeal.  140 H. 381, 400 P.3d 582 (2017).

  Under subsection (c), union-appellant, representative of real party in interest city worker, was not entitled to an award of attorney's fees incurred during a proceeding filed against worker's employer to enforce an uncontested judgment confirming an arbitration award.  119 H. 201 (App.), 194 P.3d 1163 (2008).

 

 

Notes of Decisions
Cited in 6 cases (4 in the last 5 years), 2010–2025 · leading case: Mikelson v. United Servs. Auto. Ass'n, 227 P.3d 559 (Haw. App. 2010).
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Mikelson v. United Servs. Auto. Ass'n, 227 P.3d 559 (Haw. App. 2010). · cites it 4× “This court stated that HRS § 658A-22 relates to confirmation of an arbitration award and that under HRS § 658A-25, a party may recover attorney’s fees for prevailing in a contested judicial proceeding to confirm, vacate, modify, or correct an arbitration award.”
Bennett v. Chung., 428 P.3d 778 (Haw. 2018). · cites it 2× “HRS § 658A-25(a) (Supp. 2001) provides, "[u]pon granting an order confirming, vacating without directing a hearing, modifying, or correcting an award, the court shall enter a judgment in conformity therewith.”
RTI Connectivity Pte. Ltd. v. Gateway Network Connections, LLC (D. Haw. 2023). · cites it 4× “2d 912, 920 (1998), the Court of Appeals of Maryland concluded that, under a statute substantially similar to HRS § 658A-25, “the prevailing party is entitled to recover attorneys’ fees incurred both at trial and on appeal in confirming and enforcing an arbitration award.”
Nordic PCL Constr., Inc. v. LPIHGC, LLC. ICA Order Dismissing Appeal by Hiraoka, J., filed 09/30/2024 [ada], 156 Haw. 16. Application for Writ of Certiorari, filed 11/29/2024. S.Ct. Order Accepting Application for Writ of Certiorari, filed 01/09/2025 [ada]. (Haw. 2025). · cites it 2× “In response, Nordic argued that (1) the circuit court was authorized by HRS §§ 658A-25 (2016) and 607-9 to award all of Nordic’s costs incurred in its motion to vacate the first arbitration award, including supersedeas bond premiums; (2) HRAP Rule 39 does not reserve exclusive…”
United Pub. Workers & City & Cnty. of Honolulu, 508 P.3d 1219 (Haw. App. 2022). “HRS § 658A-25 (2016) provides, in relevant part: Judgment on award; attorney's fees and litigation expenses.”
RTI Connectivity Pte. Ltd. v. Gateway Network Connections, LLC (D. Haw. 2023). “Award of Attorney’s Fees and Costs Plaintiff requests an award of reasonable attorney’s fees and costs, pursuant to Haw. Rev. Stat. § 658A-25, which states: (a) Upon granting an order confirming, vacating without directing a rehearing, modifying, or correcting an award, the…”
— Haw. Rev. Stat. § 658A-25(a) — 1 case
Bennett v. Chung., 428 P.3d 778 (Haw. 2018). “HRS § 658A-25(a) (Supp. 2001) provides, "[u]pon granting an order confirming, vacating without directing a hearing, modifying, or correcting an award, the court shall enter a judgment in conformity therewith.”
— Haw. Rev. Stat. § 658A-25(c) — 1 case
RTI Connectivity Pte. Ltd. v. Gateway Network Connections, LLC (D. Haw. 2023). “2d 912, 920 (1998), the Court of Appeals of Maryland concluded that, under a statute substantially similar to HRS § 658A-25, “the prevailing party is entitled to recover attorneys’ fees incurred both at trial and on appeal in confirming and enforcing an arbitration award.”
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