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Kumar v. Remigio

Citation: Not availableDocket: SCPW-12-0000379

Court: Hawaii Supreme Court; April 12, 2012; Hawaii; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

Raj Kumar filed a petition for a writ of mandamus seeking review of certain family court decisions, disqualification of Judge Catherine H. Remigio, and waiver of a sanction. The Supreme Court of Hawai'i, viewing the request as a petition for writ of mandamus, outlined that such writs are extraordinary remedies requiring the petitioner to demonstrate a clear right to relief and lack of alternative means for redress. The court emphasized that mandamus does not supersede the discretionary authority of lower courts and is not intended to replace normal appellate procedures. It noted that mandamus would only be applicable if the lower court exceeded its jurisdiction or committed a significant abuse of discretion. Since Kumar retains the option to appeal, the court determined that mandamus was not appropriate. The petition was ordered to be filed without a fee but was ultimately denied, leaving open the possibility for appeal.

Legal Issues Addressed

Application of Mandamus in Jurisdictional and Discretionary Abuse

Application: Mandamus may be appropriate if a lower court exceeds its jurisdiction or commits a significant abuse of discretion. However, in this case, the availability of an appeal rendered mandamus inappropriate.

Reasoning: It noted that mandamus would only be applicable if the lower court exceeded its jurisdiction or committed a significant abuse of discretion. Since Kumar retains the option to appeal, the court determined that mandamus was not appropriate.

Limits of Mandamus in Discretionary Matters

Application: The court emphasized that mandamus cannot be used to override the discretionary authority of lower courts or replace normal appellate procedures.

Reasoning: The court emphasized that mandamus does not supersede the discretionary authority of lower courts and is not intended to replace normal appellate procedures.

Nature of Mandamus Relief

Application: The court explained that mandamus is an extraordinary remedy that requires the petitioner to show a clear right to relief and no other means of redress.

Reasoning: The Supreme Court of Hawai'i, viewing the request as a petition for writ of mandamus, outlined that such writs are extraordinary remedies requiring the petitioner to demonstrate a clear right to relief and lack of alternative means for redress.

Waiver of Filing Fees in Mandamus Petitions

Application: The petition was allowed to be filed without a fee, demonstrating the court's discretion in waiving such fees even when the petition is ultimately denied.

Reasoning: The petition was ordered to be filed without a fee but was ultimately denied, leaving open the possibility for appeal.