Hawaii Revised Statutes

Haw. Rev. Stat. § 708-837 (2026)

] Failure to return a rental motor vehicle; penalty

✓ current as of July 2026

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[§708-837] Failure to return a rental motor vehicle; penalty. [(1)] A person commits the offense of failure to return a rental motor vehicle when he intentionally does not return the motor vehicle to the person, or his agent, from whom the vehicle was rented within forty-eight hours after the time stated on the rental agreement, unless the person renting the vehicle gives notice that he will not be able to return the vehicle in the stated time and extends the time in which the vehicle will be returned.

[(2)] Failure to return a rental motor vehicle is a misdemeanor. [L 1973, c 63, §1]

COMMENTARY ON §708-837

This section was added by Act 63, Session Laws 1973, "to provide an incentive to a person who rents a motor vehicle to return it to its lawful owner." House Standing Committee Report No. 821.

The Committee Report further states that "rental agencies have been plagued for a number of years with overdue and abandoned vehicles. Presently, there is no legal means available to compel a person to return the vehicle when it is overdue. This proposed bill would make it a misdemeanor if a person intentionally fails to return a rental motor vehicle."

Case Notes

Where police stopped defendant's rental car after they had received a report from the car's owner that the car was overdue, police had reasonable suspicion to stop the car, even if the report turned out to be mistaken due to its timing, because the police were acting on a police report from the car's owner, whose honesty had not been questioned. 241 F.3d 1124 (2001).

Mentioned: 86 H. 207, 948 P.2d 1048 (1997).

Notes of Decisions

Cited in 3 cases, 1994–2004 · leading case: United States v. Leigh Christina Miguel, United States of Am. v. Norman Jeremiah Johnson, 368 F.3d 1150 (9th Cir. 2004).

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United States v. Leigh Christina Miguel, United States of Am. v. Norman Jeremiah Johnson, 368 F.3d 1150 (9th Cir. 2004). “and 12 p.m. later that day. Id. Legally, though, the car was not overdue because the full 48-hour grace period had not elapsed.”

State v. Bautista, 948 P.2d 1048 (Haw. 1997). · cites it 2× “HRS § 708-837 (1993) provides in relevant part: A person commits the offense of failure to return a rental motor vehicle when he intentionally does not return the motor' vehicle to the person, or his agent, from whom the vehicle was rented within forty-eight hours after the time…”

Appell v. Sumner, 845 F. Supp. 746 (D. Haw. 1994). · cites it 2× “§§ 707-715, 707-716(l)(d), and 702-222(l)(a) and (b); Failure to Return a Rental Motor Vehicle, in violation of Haw.Rev.Stat. § 708-837; and Reckless Endangering in the Second Degree, in violation of Haw.”

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