Hawaii Revised Statutes

Haw. Rev. Stat. § 91-9 (2026)

  Contested cases; notice; hearing; interactive conference technology; records

✓ current as of July 2026
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     §91-9  Contested cases; notice; hearing; interactive conference technology; records.  (a)  Subject to section 91-8.5, in any contested case, all parties shall be afforded an opportunity for hearing after reasonable notice.

     (b)  The notice shall include a statement of:

     (1)  The date, time, place, and nature of hearing;

     (2)  The legal authority under which the hearing is to be held;

     (3)  The particular sections of the statutes and rules involved;

     (4)  An explicit statement in plain language of the issues involved and the facts alleged by the agency in support thereof; provided that if the agency is unable to state the issues and facts in detail at the time the notice is served, the initial notice may be limited to a statement of the issues involved, and thereafter upon application a bill of particulars shall be furnished; and

     (5)  The fact that any party may retain counsel if the party so desires and the fact that an individual may appear on the individual's own behalf, or a member of a partnership may represent the partnership, or an officer or authorized employee of a corporation or trust or association may represent the corporation, trust, or association.

     (c)  The hearing may be held by interactive conference technology that allows interaction by the agency, any party, and counsel if retained by the party, and the notice identifies electronic contact information for each agency, party, and counsel if retained by the party.  A contested case hearing held by interactive conference technology shall be recessed for up to one hour when audio communication cannot be maintained; provided that the hearing may reconvene when only audio communication is reestablished.  If audio-only communication is reestablished, then each speaker shall state the speaker's name prior to making remarks.

     (d)  Opportunities shall be afforded all parties to present evidence and argument on all issues involved; provided that, if the hearing is held by interactive conference technology evidence may be submitted and exchanged by electronic means.

     (e)  Any procedure in a contested case may be modified or waived by stipulation of the parties and informal disposition may be made of any contested case by stipulation, agreed settlement, consent order, or default.

     (f)  For the purpose of agency decisions, the record shall include:

     (1)  All pleadings, motions, intermediate rulings;

     (2)  Evidence received or considered, including oral testimony, exhibits, and a statement of matters officially noticed;

     (3)  Offers of proof and rulings thereon;

     (4)  Proposed findings and exceptions;

     (5)  Report of the officer who presided at the hearing; and

     (6)  Staff memoranda submitted to members of the agency in connection with their consideration of the case.

     (g)  It shall not be necessary to transcribe the record unless requested for purposes of rehearing or court review.

     (h)  No matters outside the record shall be considered by the agency in making its decision except as provided herein.

     (i)  For the purposes of this subsection, "interactive conference technology" means any form of audio or audio and visual conference technology, including teleconference, videoconference, and voice over internet protocol, that facilitates interaction between the agency, any party, and counsel if retained by the party. [L 1961, c 103, §9; Supp, §6C-9; HRS §91-9; am L 1980, c 130, §1; gen ch 1985; am L 2003, c 76, §2; am L 2021, c 168, §2]

 

Law Journals and Reviews

 

  A Litigator's Approach to Issues Concerning Exercise and Protection of Native Hawaiian Traditional and Customary Rights.  43 UH L. Rev. 592 (2021).

 

Case Notes

 

  Provision for waiver of any procedure includes procedural requirements of §91-11.  54 H. 10, 510 P.2d 358.

  Subsection (c) applied.  55 H. 538, 524 P.2d 84.

  There were no statutes which required that the prisoner be given a hearing on transfer from state to federal prison.  58 H. 386, 570 P.2d 563.

  Full hearing, what constitutes.  60 H. 166, 590 P.2d 524.

  State did not have to follow contested case procedures in canceling a lease of state land.  66 H. 632, 672 P.2d 1030.

  Particularized notice of methodology used by public utilities commission in its ratemaking determinations not required.  67 H. 425, 690 P.2d 274.

  Where board of land and natural resources improperly consulted outside sources, the violation was cured by the subsequent rehearing proceeding.  76 H. 259, 874 P.2d 1084.

  Appellant failed to show that board of medical examiners violated subsection (g), where appellant contended that board violated subsection (g) by taking testimony from hearings officer during a hearing before the board en banc about matters not contained in the record.  78 H. 21, 889 P.2d 705.

  Despite not citing to the specific relevant section of the Hawaii administrative rules (HAR), the contested case hearing notice satisfied the requirements of subsection (b), where, among other things, the notice provided an implicit reference to the HAR section because "excessive sedimentation" could only be a reference to that section.  132 H. 247, 320 P.3d 912 (2014).

  Receiving a letter from party and taking a view of the premises after the public hearing was closed were irregularities leading to reversal.  2 H. App. 43, 625 P.2d 1044.

  Not violated by agency's order that parties not make any further comments unless specifically requested.  4 H. App. 633, 675 P.2d 784.

  Cited:  904 F. Supp. 1098.

  Cited:  134 H. 187, 339 P.3d 685 (2014).

 

 

Notes of Decisions
Cited in 63 cases (9 in the last 5 years), 1970–2026 · leading case: Pila‘a 400, LLC v. Bd. of Land & Nat. Resources., 320 P.3d 912 (Haw. 2014).
Pila‘a 400, LLC v. Bd. of Land & Nat. Resources., 320 P.3d 912 (Haw. 2014). · cites it 109× “In its exceptions, Pila#a 400 raised an objection to any findings based on HAR § 13-5-24 due to a lack of notice under HRS § 91-9. Pila#a 400 stated that it had “never received any notice, oral or written, that the contested case hearing was proceeding under the marine…”
The Cmty. Associations of Hualalai, Inc. v. Leeward Plan. Comm'n., 500 P.3d 426 (Haw. 2021). · cites it 22× “SPP- 16-188 was a contested case because an agency hearing was required by the LPC rules and statutes relevant to the issuance of special permits, LPC Rule 4, 6; HRS §§ 91-9, 205-6 (referenced by HCC § 25-2-61(c)), and such a hearing would have determined the “legal rights,…”
Keep the North Shore Country v. Bd. of Land & Nat. Resources., 506 P.3d 150 (Haw. 2022). · cites it 18× “The Board observed that “[n]othing in the record shows that Member Gon has not complied or will not comply with HRS §§ 91-9(g) and 91-13.” The Board also reasoned that the fact that HRS § 195D-25 authorizes the Board chair to also serve on the Committee means there is no…”
'O Haleakalâ v. Bd. of Land & Nat. Resources, 382 P.3d 195 (Haw. 2016). · cites it 16× “See HRS §§ 91-9 to 91-13; supra. No legal authority permits contested cases before agencies to be resolved on an ex parte basis.”
E & J Lounge Operating Co. v. Liquor Comm'n of Honolulu, 189 P.3d 432 (Haw. 2008). · cites it 10× “” On the other hand, in this case, the content requirement of HRS § 91-9 would apply to notice served on Respondent and Intervenors if, pursuant to the court’s instructions, the Commission decides to hold additional hearings because, under the circumstances of this case, they…”
Outdoor Circle v. Harold K.L. Castle Trust Est., 675 P.2d 784 (Haw. App. 1983). · cites it 12× “Appellants argue that LUC committed the following reversible procedural errors: (1) it adopted conclusions of law without either a public meeting or any of the parties being present in violation of HRS §§ 92-3 and -6(b) (1976); (2) it precluded appellants from presenting…”
Sandy Beach Def. Fund v. City Council, 773 P.2d 250 (Haw. 1989). · cites it 8× “" HRS §§ 91-9 through 91-14 specify the procedural requirements for contested cases.”
State v. Gustafson, 515 P.2d 1256 (Haw. 1973). · cites it 32× “I am drawn to this conclusion for several reasons. First, the contours of the hearing outlined in HRS § 286-156 are wholly substantive, and that section is silent as to the procedures to be employed by the district judge.”
In Re Kauai Elec. Div. of Citizens Utils. Co., 590 P.2d 524 (Haw. 1978). · cites it 8× “The Commission failed to hold a “full hearing” as required by HRS § 91-9; C. It lacks specific findings of fact and conclusions of law as required by HRS § 91-12; II.”
E & J Lounge Operating Co. v. Liquor Comm'n of Honolulu, 174 P.3d 367 (Haw. App. 2007). · cites it 22× “Contested case hearings are adjudicatory in nature and their procedures are governed by HRS § 91-9 through § 9[1]-11 and also include § 91-12 and § 91-14.”
Chang v. Plan. Com'n of Cnty. of Maui, 643 P.2d 55 (Haw. 1982). · cites it 14× “This appeal is thus governed by HRS §91-14(1976& Supp.”
Kelly v. 1250 Oceanside Partners, 140 P.3d 985 (Haw. 2006). · cites it 4× “Approximately two weeks later, Oceanside requested a contested-case hearing before DOH pursuant to HRS § 91-9 (1993). 13 On December 15, 2000, Plaintiffs, Oceanside, and DOH agreed to a stipulation converting the TRO to a preliminary injunction.”
— Haw. Rev. Stat. § 91-9(1984) — 1 case
Pila‘a 400, LLC v. Bd. of Land & Nat. Resources., 320 P.3d 912 (Haw. 2014). “In its exceptions, Pila#a 400 raised an objection to any findings based on HAR § 13-5-24 due to a lack of notice under HRS § 91-9. Pila#a 400 stated that it had “never received any notice, oral or written, that the contested case hearing was proceeding under the marine…”
— Haw. Rev. Stat. § 91-9(a) — 9 cases
Outdoor Circle v. Harold K.L. Castle Trust Est., 675 P.2d 784 (Haw. App. 1983). “Appellants argue that LUC committed the following reversible procedural errors: (1) it adopted conclusions of law without either a public meeting or any of the parties being present in violation of HRS §§ 92-3 and -6(b) (1976); (2) it precluded appellants from presenting…”
The Cmty. Associations of Hualalai, Inc. v. Leeward Plan. Comm'n., 500 P.3d 426 (Haw. 2021). “SPP- 16-188 was a contested case because an agency hearing was required by the LPC rules and statutes relevant to the issuance of special permits, LPC Rule 4, 6; HRS §§ 91-9, 205-6 (referenced by HCC § 25-2-61(c)), and such a hearing would have determined the “legal rights,…”
Korean Buddhist Dae Won Sa Temple v. Sullivan, 953 P.2d 1315 (Haw. 1998).
E & J Lounge Operating Co. v. Liquor Comm'n of Honolulu, 189 P.3d 432 (Haw. 2008). “” On the other hand, in this case, the content requirement of HRS § 91-9 would apply to notice served on Respondent and Intervenors if, pursuant to the court’s instructions, the Commission decides to hold additional hearings because, under the circumstances of this case, they…”
In Re Kauai Elec. Div. of Citizens Utils. Co., 590 P.2d 524 (Haw. 1978). “The Commission failed to hold a “full hearing” as required by HRS § 91-9; C. It lacks specific findings of fact and conclusions of law as required by HRS § 91-12; II.”
— Haw. Rev. Stat. § 91-9(b) — 5 cases
Pila‘a 400, LLC v. Bd. of Land & Nat. Resources., 320 P.3d 912 (Haw. 2014). “In its exceptions, Pila#a 400 raised an objection to any findings based on HAR § 13-5-24 due to a lack of notice under HRS § 91-9. Pila#a 400 stated that it had “never received any notice, oral or written, that the contested case hearing was proceeding under the marine…”
Chang v. Plan. Com'n of Cnty. of Maui, 643 P.2d 55 (Haw. 1982). “This appeal is thus governed by HRS §91-14(1976& Supp.”
E & J Lounge Operating Co. v. Liquor Comm'n of Honolulu, 174 P.3d 367 (Haw. App. 2007). “Contested case hearings are adjudicatory in nature and their procedures are governed by HRS § 91-9 through § 9[1]-11 and also include § 91-12 and § 91-14.”
State v. Gustafson, 515 P.2d 1256 (Haw. 1973). “I am drawn to this conclusion for several reasons. First, the contours of the hearing outlined in HRS § 286-156 are wholly substantive, and that section is silent as to the procedures to be employed by the district judge.”
— Haw. Rev. Stat. § 91-9(b)(3) — 1 case
Pila‘a 400, LLC v. Bd. of Land & Nat. Resources., 320 P.3d 912 (Haw. 2014). “In its exceptions, Pila#a 400 raised an objection to any findings based on HAR § 13-5-24 due to a lack of notice under HRS § 91-9. Pila#a 400 stated that it had “never received any notice, oral or written, that the contested case hearing was proceeding under the marine…”
— Haw. Rev. Stat. § 91-9(b)(4) — 2 cases
Pila‘a 400, LLC v. Bd. of Land & Nat. Resources., 320 P.3d 912 (Haw. 2014). “In its exceptions, Pila#a 400 raised an objection to any findings based on HAR § 13-5-24 due to a lack of notice under HRS § 91-9. Pila#a 400 stated that it had “never received any notice, oral or written, that the contested case hearing was proceeding under the marine…”
Scott v. Contractors License Bd., 626 P.2d 199 (Haw. App. 1981).
— Haw. Rev. Stat. § 91-9(b)(5) — 1 case
Pila‘a 400, LLC v. Bd. of Land & Nat. Resources., 320 P.3d 912 (Haw. 2014). “In its exceptions, Pila#a 400 raised an objection to any findings based on HAR § 13-5-24 due to a lack of notice under HRS § 91-9. Pila#a 400 stated that it had “never received any notice, oral or written, that the contested case hearing was proceeding under the marine…”
— Haw. Rev. Stat. § 91-9(c) — 12 cases
'O Haleakalâ v. Bd. of Land & Nat. Resources, 382 P.3d 195 (Haw. 2016). “See HRS §§ 91-9 to 91-13; supra. No legal authority permits contested cases before agencies to be resolved on an ex parte basis.”
The Cmty. Associations of Hualalai, Inc. v. Leeward Plan. Comm'n., 500 P.3d 426 (Haw. 2021). “SPP- 16-188 was a contested case because an agency hearing was required by the LPC rules and statutes relevant to the issuance of special permits, LPC Rule 4, 6; HRS §§ 91-9, 205-6 (referenced by HCC § 25-2-61(c)), and such a hearing would have determined the “legal rights,…”
Town v. Land Use Comm'n, 524 P.2d 84 (Haw. 1974).
In Re Kauai Elec. Div. of Citizens Utils. Co., 590 P.2d 524 (Haw. 1978). “The Commission failed to hold a “full hearing” as required by HRS § 91-9; C. It lacks specific findings of fact and conclusions of law as required by HRS § 91-12; II.”
— Haw. Rev. Stat. § 91-9(d) — 1 case
Application of Hawaiian Tel. Co., 651 P.2d 475 (Haw. 1982).
— Haw. Rev. Stat. § 91-9(e) — 7 cases
Kilakila 'O Haleakala v. Univ. of Hawaii., 382 P.3d 176 (Haw. 2016).
'O Haleakalâ v. Bd. of Land & Nat. Resources, 382 P.3d 195 (Haw. 2016). “See HRS §§ 91-9 to 91-13; supra. No legal authority permits contested cases before agencies to be resolved on an ex parte basis.”
Wah Tim Chock v. Bitterman, 678 P.2d 576 (Haw. App. 1984).
Rife v. Akiba, 912 P.2d 581 (Haw. App. 1996).
— Haw. Rev. Stat. § 91-9(f) — 2 cases
E & J Lounge Operating Co. v. Liquor Comm'n of Honolulu, 174 P.3d 367 (Haw. App. 2007). “Contested case hearings are adjudicatory in nature and their procedures are governed by HRS § 91-9 through § 9[1]-11 and also include § 91-12 and § 91-14.”
You v. Minami, 652 P.2d 632 (Haw. 1982).
— Haw. Rev. Stat. § 91-9(g) — 6 cases
Keep the North Shore Country v. Bd. of Land & Nat. Resources., 506 P.3d 150 (Haw. 2022). “The Board observed that “[n]othing in the record shows that Member Gon has not complied or will not comply with HRS §§ 91-9(g) and 91-13.” The Board also reasoned that the fact that HRS § 195D-25 authorizes the Board chair to also serve on the Committee means there is no…”
The Cmty. Associations of Hualalai, Inc. v. Leeward Plan. Comm'n., 500 P.3d 426 (Haw. 2021). “SPP- 16-188 was a contested case because an agency hearing was required by the LPC rules and statutes relevant to the issuance of special permits, LPC Rule 4, 6; HRS §§ 91-9, 205-6 (referenced by HCC § 25-2-61(c)), and such a hearing would have determined the “legal rights,…”
'O Haleakalâ v. Bd. of Land & Nat. Resources, 382 P.3d 195 (Haw. 2016). “See HRS §§ 91-9 to 91-13; supra. No legal authority permits contested cases before agencies to be resolved on an ex parte basis.”
Loui v. Bd. of Med. Examiners, 889 P.2d 705 (Haw. 1995).
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