Hawaii Revised Statutes

Haw. Rev. Stat. § 92-3 (2026)

  Open meetings

✓ current as of July 2026
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     §92-3  Open meetings.  Every meeting of all boards shall be open to the public and all persons shall be permitted to attend any meeting unless otherwise provided in the state constitution or as closed pursuant to sections 92-4 and 92-5; provided that the removal of any person or persons who wilfully disrupts a meeting to prevent and compromise the conduct of the meeting shall not be prohibited.  The boards shall afford all interested persons an opportunity to submit data, views, or arguments, in writing, on any agenda item.  The boards shall also afford all interested persons an opportunity to present oral testimony on any agenda item; provided that the oral testimonies of interested persons shall not be limited to the beginning of a board's agenda or meeting.  The boards may provide for reasonable administration of oral testimony by rule. [L 1975, c 166, pt of §1; am L 1985, c 278, §1; am L 2022, c 264, §4]

 

Attorney General Opinions

 

  Sunshine law applies to meeting of standing or select committee of board of regents of University of Hawaii.  Att. Gen. Op. 85-27.

  Opportunity to present testimony, when it must be afforded; cannot delegate committee to hear testimony.  Att. Gen. Op. 86-5.

 

Case Notes

 

  Rule regarding confidentiality of development proposals neither conflicted with nor contradicted “mandate” of either this section or the Sunshine Law, chapter 92, as a whole; plaintiff not entitled to disclosure of development proposals under those statutory provisions.  74 H. 365, 846 P.2d 882.

 

 

Notes of Decisions
Cited in 16 cases (3 in the last 5 years), 1982–2026 · leading case: Civil Beat Law Ctr. for the Pub. Interest, Inc. v. City & Cnty. of Honolulu, 445 P.3d 47 (Haw. 2019).
Civil Beat Law Ctr. for the Pub. Interest, Inc. v. City & Cnty. of Honolulu, 445 P.3d 47 (Haw. 2019). · cites it 16× “Counts 1 and 2 In Counts 1 and 2, Civil Beat sought declaratory relief interpreting the Sunshine Law's open meeting requirement, HRS § 92-3, and criminal penalties provision, HRS § 92-13.”
Kaapu v. Aloha Tower Dev. Corp., 846 P.2d 882 (Haw. 1993). · cites it 20× “On December 21,1989, the ATDC conducted an open public meeting (the public meeting), in accordance with HRS § 92-3 (1985 and Supp. 1992), 7 for the purpose of making the final selection of a developer with which to enter into negotiations for a long-term lease of the *376…”
Kanahele v. Maui Cnty. Council., 307 P.3d 1174 (Haw. 2013). · cites it 25× “The concurrence explained that pursuant to HRS § 92-3, all board meetings must be open to the public.”
Outdoor Circle v. Harold K.L. Castle Trust Est., 675 P.2d 784 (Haw. App. 1983). · cites it 4× “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…”
Chang v. Plan. Com'n of Cnty. of Maui, 643 P.2d 55 (Haw. 1982). · cites it 6× “Finally, appellant seeks the voidance of Makena Surfs SMA use permit for the planning commission’s failure to open its final deliberations on the permit application and on appellant’s motion for reconsideration and petition for declaratory ruling to the public in violation of…”
E & J Lounge Operating Co. v. Liquor Comm'n of Honolulu, 189 P.3d 432 (Haw. 2008). · cites it 2× “, contested case hearings, the Maui Planning Commission’s "closed deliberations on [the] permit application and on appellant’s subsequent motion and petition were permissible under HRS § 92—6(a)(2) despite the open-meeting mandate of HRS § 92-3.”) . The ICA maintained that…”
Bremner v. City & Cnty. of Honolulu, 28 P.3d 350 (Haw. App. 2001). · cites it 2× “HRS § 92-3 (1993). Persons alleging a violation of this provision must file a complaint within ninety days of the violation.”
Right to Know Comm. v. City Council, 175 P.3d 111 (Haw. App. 2008). · cites it 2× “” HRS § 92-3 (1993) (footnote not in original).”
In re Attorney's Fees to McLaren v. Paradise Inn Hawaii, Inc., 321 P.3d 671 (Haw. 2014). · cites it 2× “HRS § 92-3 provides: Every meeting of all boards shall be open to the public and all persons shall be permitted to attend any meeting unless otherwise provided in the constitution or as closed pursuant to sections 92-4 and 92-5; provided that the removal of any person or persons…”
Kahana Sunset Owners Ass'n v. Maui Cnty. Council, 948 P.2d 122 (Haw. 1997). · cites it 2× “anting JGL’s and the County Defendants’ motion for summary judgment, alleging as points of error: (1) the conditions imposed by the Council in Ordinance 2317 were insufficient to protect the public, from the effects of the rezoning; (2) by law, the Council was required to…”
Disabato v. South Carolina Ass'n of Sch. Administrators, 746 S.E.2d 329 (S.C. 2013). “§§ 50-14-1 & 50-18-70-77; Haw. Rev.Stat. §§ 92-3 & 92F-1-119; Idaho Code Ann.”
Cnty. of Kauai v. OIP, 200 P.3d 403 (Haw. App. 2009). · cites it 14× “" The circuit court found the following: *405 Moreover, [Hawaii Revised Statutes (HRS) ] § 92-12(c) provides that any person may commence a suit in the circuit court to seek enforcement of the open meetings provisions of HRS § 92-3. This Court notes that within the provisions of…”
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