Hawaii Revised Statutes

Haw. Rev. Stat. § 661-3 (2026)

  No jurisdiction, when

✓ current as of July 2026
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     §661-3  No jurisdiction, when.  No person shall file or prosecute under this part any claim for or in respect to which that person or any assignee of that person has pending an action against a person who, at the time when the claim alleged in the action arose, was, in respect thereto, acting or professing to act, directly or indirectly, under the authority of the State. [L 1894-5, c 26, §3; RL 1925, §2671; RL 1935, §4422; RL 1945, §10477; RL 1955, §245-3; HRS §661-3; am L 1972, c 164, §1(c); am L 2016, c 55, §42]

 

Case Notes

 

  Section does not prevent joinder of State and person who acted or professed to act under State's authority as defendants in one suit.  9 H. App. 21, 821 P.2d 937 (1991).

  Where plaintiffs brought individual and class action claims against only the employees' retirement system and did not file a lawsuit against the State while there was a pending action against a person acting under state authority, this section did not bar the circuit court from having jurisdiction.  121 H. 462 (App.), 220 P.3d 1043 (2009).

 

 

Notes of Decisions
Cited in 4 cases, 1976–2009 · leading case: Fratinardo v. Employees' Ret. Sys. of the State of Hawai'i, 220 P.3d 1043 (Haw. App. 2009).
Fratinardo v. Employees' Ret. Sys. of the State of Hawai'i, 220 P.3d 1043 (Haw. App. 2009). · cites it 9× “Next, ERS argues that, upon the filing of a petition to the Board for a contested case hearing on Plaintiffs’ individual claims, Plaintiffs’ class action claims are in violation of HRS § 661-3 (1993).”
Marshall v. Univ. of Hawai'i, 821 P.2d 937 (Haw. App. 1991). · cites it 2× “UH argues that under Hawai'i Revised Statutes (HRS) § 661-3 (1985) 6 the lower court had no jurisdiction to entertain Counts I and II.”
Brown v. Wong, 795 P.2d 283 (Haw. 1990). · cites it 2× “The argument made below, as best we can understand it, was that the appellee’s claims were really tort claims, not contract claims, and that because appellee had joined tort claims with the contract claim in her complaint, she was prohibited by HRS § 661-3 from pursuing the…”
Hawaiian Land Co. v. Kamaka, 547 P.2d 581 (Haw. 1976). · cites it 2× “As held in Hawaiian Trust, there is an implied contract on the part of the State, within the meaning of HRS § 661-3 3 to pay the actual *662 earnings of the principal sum to the petitioners and a complaint stating a claim for relief (assumpsit) for money had and received would…”
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